UK Packaging EPR: What Brands Need to Know

This guide is general information, not legal or compliance advice.

UK packaging EPR (extended producer responsibility) makes the businesses that put packaging on the UK market responsible for reporting it and, if they are large producers, for paying towards the cost of collecting and dealing with it as waste. You are only obligated if your business is established in the UK, has a worldwide turnover of £1 million or more and handled more than 25 tonnes of packaging in the previous year. Everything below was checked against GOV.UK guidance on 11 September 2026; the scheme changes often, so check the current GOV.UK pages before you act.

What UK packaging EPR is

EPR for packaging is set out in the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, which apply across England, Wales, Scotland and Northern Ireland. The idea is simple: the business that decides to use packaging should carry the cost of what happens to it afterwards, rather than local councils and taxpayers.

In practice the scheme has four moving parts:

• Registration with your environmental regulator (the Environment Agency, Natural Resources Wales, SEPA or the Northern Ireland Environment Agency).
• Reporting the packaging you supplied or imported, by material and weight, through the government's Report Packaging Data service.
• Waste disposal fees, paid by large producers to PackUK, the scheme administrator, for household and commonly binned packaging.
• Recycling obligations, met by large producers buying packaging waste recycling notes (PRNs) and export notes (PERNs).

Custom Boxez is a packaging supplier, not a compliance adviser, so we cannot tell you whether your business is obligated. What we can do is explain how the scheme works and help you get accurate information about the boxes you buy from us. If you are unsure, read the GOV.UK guidance or speak to a compliance scheme or adviser.

Who is an obligated producer?

GOV.UK describes a "producer of packaging" as a business that carries out any of these activities:

• supplying filled packaging under its own brand;
• packing goods or filling packaging;
• importing goods in packaging;
• supplying unfilled packaging that it manufactures or imports;
• hiring or loaning out reusable packaging;
• owning an online marketplace through which packaging is supplied in the UK from outside the UK;
• selling filled packaging to an end user, whether a consumer or a business.

Being a producer does not automatically mean you have obligations. You become an obligated producer only if all of the following apply: you are established in the UK, you supplied or imported more than 25 tonnes of packaging in the UK in the previous year, and your annual worldwide turnover was £1 million or more. For 2026 packaging data, GOV.UK says to count packaging supplied from 1 January to 31 December 2025 and to take turnover from the last accounts available before 7 April 2026. Charities are exempt, although their trading subsidiaries are not.

Small and large producers

Obligated producers are either small or large. The table reproduces GOV.UK's thresholds as published in August 2026.

Corporate groups apply the test to the combined figures of the UK companies in the group that supply or import packaging, and every member then takes the group's classification.

What large and small producers must do

The two tiers have very different workloads. This is how GOV.UK summarises them.

Producers can register and report themselves or through a compliance scheme. One exception applies: GOV.UK is clear that a compliance scheme cannot pay waste disposal fees on a producer's behalf.

What data you report, and when

Reporting is by weight and material. The material categories used in the scheme are aluminium, fibre-based composite, glass, paper and card, plastic, steel, wood and "other". Large producers also record the packaging activity (for example brand owner, packer or importer), the type of packaging (such as primary, secondary, shipment, household or non-household, and packaging that commonly ends up in public bins) and, subject to the regulators' current position statements, which UK nation it was supplied in.

For a custom printed box that means knowing, per unit, the weight of the board and the weight of anything that is not board: a plastic window, a foam insert, magnets, ribbon. Multiply by the quantity supplied in the period and you have the figures your report needs.

Reporting deadlines for 2026 data

If you miss a deadline, GOV.UK advises contacting your environmental regulator. Changing data after submission can carry a resubmission fee.

Fees: what large producers pay

Large producers face three kinds of cost: registration fees to the regulator, waste disposal fees to PackUK, and the market cost of the PRNs and PERNs they buy to meet their recycling obligations. Small producers pay a registration fee only.

Waste disposal fees apply only to packaging classed as household, packaging that is commonly binned, and glass household drinks containers. They are calculated per tonne, by material, from the previous year's data, and they have been invoiced since October 2025. PackUK issues a notice of liability through the Report Packaging Data service, usually payable in quarterly instalments.

The first confirmed rates were the 2025 base fees, calculated from 2024 packaging data and invoiced from October 2025:

These figures are for the first fee year only. Fees for 2026 to 2027 are calculated differently, as the next section explains, and PackUK's operational plan says it intends to issue the initial notices of liability for that year by the end of November 2026. Check GOV.UK for the confirmed rates that apply to you.

Recycling obligations are a percentage of the packaging you report. GOV.UK's business targets for 2026 are 77% for paper, board and fibre-based composite, and 57% for plastic, rising again in 2027. Evidence for the 2026 obligation year must be in place by 31 January 2027.

Modulation: why recyclability now affects the fee

From the 2026 to 2027 fee year, waste disposal fees are modulated. PackUK's modulation statement (updated February 2026) says the first modulated fees use data on packaging supplied in 2025.

Modulation works within each material category using the Recyclability Assessment Methodology (RAM), which gives household packaging a red, amber or green rating:

• Green: widely recyclable in current UK infrastructure. Green-rated material receives a discount.
• Amber: may face challenges in collection, sorting or reprocessing. Amber is charged the base rate.
• Red: difficult to recycle at scale. Red-rated material is charged the base rate multiplied by a modulation factor.

The extra money raised from red-rated material funds an equal percentage discount on every tonne of green-rated material across all categories. So two paper-based boxes of the same weight can carry different fees if one is rated green and the other red.

Which RAM version applies

GOV.UK says large producers use RAM version 1.1 for the 2026 reporting year and RAM 2027, published by PackUK on 1 July 2026, for packaging supplied from 1 January to 31 December 2027. For paper and board, RAM 2027 looks at things such as the proportion of non-paper content, certain coatings and laminations, glitter, and components too small to be sorted. It also rates some packaging red automatically, including boxes with integrated electrical components such as LED lights.

For the practical design side, see recyclable packaging materials and our sustainable packaging guide.

Key dates at a glance

How packaging choices affect your EPR costs

Because reporting and fees are by weight and material, three packaging decisions matter most if you are obligated:

1. Weight. A box that is larger than it needs to be, or uses a heavier board than the product requires, adds tonnage. Our guide to reducing excess packaging covers right-sizing.
2. Material mix. Every non-board component has to be reported under its own material, and plastic components may also fall under Plastic Packaging Tax. Board inserts in place of foam, or an open window instead of a film patch, reduce the number of materials you report.
3. Recyclability rating. Heavy non-paper content, some laminations and coatings, glitter and built-in electronics can push a paper-based box towards amber or red under RAM 2027.

We do not give RAM ratings for specific constructions, because the assessment is the producer's to make against the current methodology. What we can do is specify the board, finish and components clearly on your quotation so you have the facts to assess. Tell us in your quote request if EPR reporting is a factor and which information you need.

Common mistakes

• Assuming your supplier is responsible. For branded packaging, the obligation usually sits with the brand owner, not the box maker.
• Using last year's figures. Fees, targets, deadlines and the RAM version have changed every year so far. Always check the current GOV.UK guidance.
• Counting only the outer box. Inserts, windows, tissue, labels and shipping packaging all count towards your tonnage and data.
• Treating RAM ratings as labels. A green RAM rating does not by itself justify a "recyclable" claim on pack, and a recycling label is not a RAM assessment.
• Leaving data collection until the deadline. Capture component weights at order stage for every packaging line you buy.