Extended Producer Responsibility

In 2026, the Extended Producer Responsibility (EPR) regulations have significantly tightened for small to medium-sized enterprises (SMEs) in the UK. The most important change for your business is that the “reporting threshold” has been lowered, pulling many companies into the regulatory net for the first time.

Here is a summary of how these regulations affect SMEs based on their size and turnover.

Do You Qualify? (The Thresholds)

Your obligations depend on whether you are classified as a Small or Large producer.

Note: If you are below both the £1m turnover and 25-tonne packaging limit, you generally have no direct obligations under EPR.

Requirements for “Small Producers”

If you fall into the Small Producer category, your burden is primarily administrative rather than financial.

• Registration: You must register with the Environment Agency (if based in England) and pay an annual fee (typically around £1,303, or less if you use a compliance scheme).
• Data Reporting: You must report the type and weight of packaging you supply to the UK market once a year (usually by April 1st for the previous year’s data).
• No Waste Fees: Crucially, small producers do not have to pay the “Local Authority Waste Management” fees or purchase Packaging Recovery Notes (PRNs).

Requirements for “Large Producers”

If your SME has grown into the Large Producer category, the impact is much heavier:

• Twice-Yearly Reporting: You must submit granular packaging data every six months.
• Financial Liability: You are responsible for paying the full net cost of managing your packaging waste. This includes fees to local authorities for collecting and recycling your household-bound packaging.
• Eco-Modulation (New for 2026): Your fees are now “modulated” based on how recyclable your packaging is. Using “Green-rated” (highly recyclable) materials results in lower fees, while “Red-rated” materials attract escalating penalties (up to 1.2 x base fee in 2026).

Immediate Deadlines & Actions for 2026

• April 1, 2026 (Labelling): All packaging (except flexible films) must now carry a mandatory “Recycle” or “Do Not Recycle” logo.
• Data Accuracy: Ensure you are tracking packaging by material (plastic, glass, paper, etc.) and category (household vs. non-household).
• Nation of Sale Reporting: You may be required to report where in the UK your packaging is sold (England, Scotland, Wales, or NI).