EPR (Extended Producer Responsibility) for UK packaging manufacturers

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is a policy approach that seeks to hold manufacturers responsible for the entire lifecycle of their products. It is a key part of the circular economy, which aims to reduce waste and promote the reuse and recycling of resources.

Traditionally, manufacturers have only been responsible for their products until they are sold to consumers. Once the product is in the hands of the consumer, it becomes their responsibility to dispose of it. However, this approach has led to a significant amount of waste, as many products are not disposed of properly and end up in landfills or the environment. EPR shifts the responsibility back to the manufacturer. This means that they are responsible for the entire lifecycle of their products, from the design phase to the end of their useful life.

Manufacturers are required to take steps to reduce the environmental impact of their products, including using sustainable materials, designing products that can be easily recycled, and setting up systems to collect and dispose of their products at the end of their useful life.

Specifically within the plastic packaging sector, EPR aims to encourage sustainable design. According to a report from OPRL ltd, 59% of the surveyed population consider EPR as a “real game-changer for the UK packaging industry,” while 56% believe it will “significantly transform packaging design.” These optimistic responses suggest that EPR will serve as a compelling motivator.

When does EPR start in the UK?

Starting in 2024, producers will be required to pay fees, which will then be adjusted based on the recyclability of their packaging from 2025 onwards.

Since January 1, 2023, packaging companies responsible for handling and supplying packaging need to have commenced gathering the relevant data related to the responsibilities listed below.

What are the challenges of implementing EPR?

Despite its many benefits, EPR is not without its challenges. One of the biggest is ensuring that manufacturers comply with the policy. This requires strong regulatory frameworks and effective enforcement mechanisms. Another challenge is the cost of implementing EPR programs. Manufacturers may be reluctant to take on the additional costs associated with EPR, which could lead to higher prices for consumers.

Overall, however, EPR is an important policy approach that has the potential to significantly reduce waste and promote the reuse and recycling of resources. By holding manufacturers responsible for the entire lifecycle of their products, the UK benefits from a more sustainable and circular economy with implications for both the environment and the economy.

Will EPR apply to your business?

The regulations will affect all UK organisations that supply packaging to consumers and businesses. You should submit packaging data if you meet all of the following criteria:

  • You are an individual business, subsidiary, or group (excluding charities)
  • Your most recent annual accounts show an annual turnover of £1 million or more
  • You are accountable for over 25 tonnes of packaging within a calendar year (January to December)

As a manufacturer, what may your responsibilities be?

  • Gathering and disclosing data on packaging you handled or supplied
  • Settling a waste management fee
  • Purchasing recycling notes (PRNs or PERNs) for fulfilling recycling obligations on packaging waste export
  • Providing “nation data” which entails information about packaging sales, hires, loans, gifts, or disposals.


Further guidance on the specifics of these points can be found on the Gov.uk website.

You can also contact us for further information and we will be happy to give advice and support.