What is EPR?: Extended Producer Responsibility for Packaging

Establishing a new way that businesses must account for their packaging use, EPR (or pEPR) will impact many groups and individuals. As a result, these changes will impact how we at Origin operate, as well as similar packaging production companies, our customers and end users, concerning the recyclability of packaging.

To inform you of what these changes comprise and what action you may need to take, we’ve put together this guide to EPR. In this blog, we cover what EPR is and how it will affect various groups.

What is EPR?

EPR, or Extended Producer Responsibility for packaging, is a framework introduced by the British government in 2023, designed to promote accountability for businesses when creating and using packaging.

The aim of EPR is for producers to pay the full net costs of managing and recycling the packaging waste arising from products they place on the UK market. This will be done by the fees paid for as part of EPR going to local authorities to fund household kerbside refuse and recycling collections.

The thinking behind EPR is that it will help to drive further circularity of packaging by reducing unnecessary and difficult-to-recycle packaging and increasing recycling.

Who is Affected?

EPR for packaging will apply to your organisation if you meet all of these criteria. If so, you must collect and report your packaging data:

• Business Type: You’re an individual business, subsidiary, or group (not including charities).
• Annual Turnover: Your annual turnover is £1 million or more, based on your most recent annual accounts up to 7 April.
• Packaging Volume: You were responsible for importing or supplying more than 25 tonnes of packaging to the UK market in the previous calendar year.
• Packaging Activities: You engage in activities such as manufacturing, importing, or selling packaged goods.

How EPR Affects Origin

Under EPR, Origin Packaging Limited is defined as a Large Organisation. We are obligated to report on packaging:

• manufactured or imported; and
• supplied to any person, other than:
  • a Large Organisation that fills or packs the packaging before supplying it to any other person or
  • a Large Organisation that is a Brand Owner.

What constitutes a ‘Large’ or ‘Small’ Organisation can be found under the “What You Need to Do” section below.

How EPR Affects Our Customers

Some of our customers may be defined as a Large Organisation Packer/Filler or a Large Organisation Brand Owner under the regulations, and they may have an EPR obligation on the packaging that Origin supplies to them.

Businesses that use substantial quantities of packaging to contain products will be affected by EPR. These will have the responsibility to report their packaging data and, if defined as a Large Organisation, pay the resulting fees involving the disposal of their waste.

As part of our reporting responsibilities, we may be in touch with customers to clarify their organisation’s definition under the regulations. If we do contact you, we would appreciate a swift response to any request for information.

It is possible that those organisations who are obligated to pay EPR fees will look to recoup them from their customers, meaning the whole supply chain could see an increase in their costs.

How EPR Affects End Users

Some companies may pass on the cost of EPR for packaging to customers, in turn making their products more expensive. However, this may deter some consumers if businesses do not optimise their packaging choices and processes to maintain the affordability of their products.

What You Need to Do

If your business meets the criteria listed in the “Who Is Affected?” section above, you must collect and report on data regarding the packaging that your business supplies or imports. This involves four main aspects:

• Packaging activity – involving supplying under your brand, packing or filling, or importing.
• Packaging type – involving whether the packaging is household or non-household.
• Packaging class – concerning whether the packaging is primary, secondary, shipment or tertiary.
• Packaging material and weight.

There are two classifications: Small Company and Large Company. These are defined as follows:

Small Company

• Your annual turnover is between £1 million and £2 million, and you’re responsible for supplying or importing more than 25 tonnes of packaging in the UK  
• Your annual turnover is over £1 million, and you’re responsible for supplying or importing between 25 tonnes and 50 tonnes of packaging in the UK

Large Company

• You have an annual turnover of £2 million or more   
• You’re responsible for supplying or importing more than 50 tonnes of packaging in the UK   

After reporting, Large Companies must pay any fees associated with the packaging that they import or supply and its management as waste.

If you do need to take action, you can register an account and report your packaging data through the GOV.UK website, with more extensive information on EPR found on the website of the scheme administrator, PACKUK. Or, we recommend speaking with a specialist in this area.

When Do You Need to Pay, and What Will the Costs Be?

EPR fees have been deferred for 1 year. The first fees will now be invoiced in October 2025 for packaging purchased in 2024; at this stage, the costs have yet to be confirmed.

Illustrative base fees have been released, indicating the estimated costs that you may have to pay per material. Updated figures can be found here.

In Summary

As discussed above, EPR will lead to large changes in how packaging is managed and accounted for by many, and may lead to a greater demand for easier-to-recycle packaging in the future.

The main takeaway business owners should bear in mind is that they will need to report their packaging usage if they meet the criteria listed in the “Who Is Affected?” section above. Larger businesses, as defined in the “What You Need to Do” section, will have to pay associated costs for their packaging use. By preparing for the actions required as a result of EPR sooner rather than later, businesses can prepare for any previously unanticipated costs ahead of time.

Should you need any further assistance with your business and EPR, we recommend getting in touch with a specialist waste consultant.