Who Needs to Register for Packaging EPR? A Simple Guide

Extended Producer Responsibility for packaging is now fully operational in the UK. The reformed scheme launched in April 2025, the first data submissions have been filed, and fee invoices are being issued to obligated producers across the country. Yet the single most common question we hear from businesses is still the most fundamental one: do I actually need to register?

The answer depends on what your business does with packaging and how much of it you handle. The rules are not complicated once you understand the structure, but the consequences of getting the answer wrong are serious. Registering unnecessarily wastes money. Failing to register when you should have done triggers penalties, back-dated fees, and regulatory enforcement action that costs far more than the compliance itself.

This guide breaks down exactly who needs to register for packaging EPR, what the thresholds are, who counts as a producer, what exemptions exist, and what happens if you get it wrong. We will work through real-world examples so you can determine your own obligation status with confidence.

The Two Thresholds: Turnover and Tonnage

EPR registration is determined by two criteria that must both be met: annual turnover and annual packaging tonnage. If your business exceeds both thresholds, you are obligated. If you fall below either threshold, you are not obligated — at least for the current compliance year.

There are two tiers of obligation with different thresholds:

What Counts Towards Turnover?

The turnover figure is your total UK annual turnover for the preceding financial year. This is not limited to packaging-related revenue. It is your total business turnover as reported in your accounts. If your business had a turnover of £1.5 million from selling products and £600,000 from providing services, your total turnover is £2.1 million and you exceed the large producer threshold.

For businesses that are part of a corporate group, the turnover threshold applies at the individual company level, not the group level. A subsidiary with £800,000 turnover is below both thresholds even if the parent group turns over £50 million. However, the packaging tonnage handled by the subsidiary still needs to be accounted for — it may be reported through the parent if the group chooses consolidated reporting.

What Counts Towards Tonnage?

The tonnage threshold refers to the total weight of packaging your business handles in a calendar year, measured in metric tonnes. This includes all packaging activities: packaging you manufacture, packaging you import (including the packaging around imported goods), packaging you fill, and packaging you sell as empty containers.

The critical point is that this is total packaging handled, not packaging placed on the market for the first time. If you import 30 tonnes of packaged goods from Europe and also fill 25 tonnes of bottles domestically, your total packaging handled is 55 tonnes and you exceed the large producer threshold.

Who Counts as a “Producer”?

The EPR regulations define several categories of producer. Understanding which category your business falls into is essential because it determines what packaging you must report on. You can be a producer in more than one category simultaneously.

Brand Owners

If your brand name appears on the packaging, you are a brand owner for EPR purposes. This is the most common producer type. It covers the company whose logo, name, or trademark is on the primary sales packaging that the consumer sees. If you design and specify the packaging for your own-brand products, you are the brand owner regardless of who physically manufactures or fills the packaging.

Importers

If you bring packaged goods into the UK from overseas, you are an importer. This applies whether you import finished products for resale, components in packaging for assembly, or raw materials in packaging for manufacturing. The packaging that accompanies imported goods becomes your responsibility under EPR, even if you had no involvement in specifying or designing that packaging. This catches many businesses by surprise — if you import wine from France, the bottles, labels, caps, and shipping cases all count as your packaging obligation.

Fillers / Packers

If you fill or pack goods into packaging on behalf of another business (contract filling, co-packing), you may be the obligated party. The rules depend on whether the brand owner has their own EPR registration. If the brand owner is registered and reports the packaging themselves, the filler is not double-obligated. But if the brand owner is not registered (for example, because they are below the thresholds), the filler may pick up the obligation if they meet the thresholds themselves.

Sellers of Empty Packaging

If your business manufactures or supplies empty packaging to other businesses (boxes, bags, bottles, tubes, wrapping), you are a producer in the “seller” category. This includes packaging wholesalers, packaging manufacturers who sell direct, and distributors of packaging materials. The obligation here is on the empty packaging itself, not on the goods that will eventually go into it.

Online Marketplaces

The reformed EPR rules brought online marketplaces into scope for the first time. If you operate a platform where third-party sellers offer goods to UK consumers, you may have obligations for the packaging of goods sold through your platform, particularly where the third-party sellers are based overseas and would otherwise escape UK EPR obligations. The marketplace operator becomes the “deemed producer” for packaging supplied by non-UK sellers through the platform.

Distributors

If you distribute packaged goods under your own name but using another company's brand packaging (for example, you are the sole UK distributor for an overseas brand), you may have obligations depending on whether the brand owner is registered in the UK. If the overseas brand has no UK EPR registration, the UK distributor picks up the obligation.

Who Is Exempt?

There are limited exemptions from EPR registration. Understanding these helps you confirm whether your business falls outside the scope entirely.

• Businesses below both thresholds: If your turnover is at or below £1 million, or your total packaging handled is at or below 25 tonnes, you are not obligated. You do not need to register and you have no reporting obligations. However, you should reassess annually.
• Charities and not-for-profit organisations: Organisations that are registered charities or genuine not-for-profit entities are generally exempt, provided they meet specific criteria. However, trading subsidiaries of charities that operate commercially may still be caught.
• Packaging that never reaches the UK market: If you manufacture packaging that is exported and never placed on the UK domestic market, that packaging is outside scope. Transit packaging used solely for export shipments is also excluded. But if the same packaging is used for both domestic and export shipments, only the domestic portion is exempt from export.
• Reusable transit packaging in a closed loop: Certain reusable transit packaging (such as reusable pallets, crates, or containers) that operates in a genuine closed-loop system — meaning it is returned, reused, and never enters the waste stream — may be excluded. However, the burden of proof is on the producer to demonstrate the closed-loop system is genuine and effective.

It is worth emphasising what is not an exemption. Being a small business does not exempt you if you exceed the thresholds. Having a compliance scheme does not remove the registration obligation (you must still register; the scheme manages some of the downstream obligations). Using recyclable packaging does not exempt you from registration (though it may reduce your fees through better RAM ratings).

How to Register: Step by Step

If you have determined that your business exceeds the thresholds and qualifies as a producer, here is the registration process.

Step 1: Gather Your Information

Before starting the registration, collect the following: your Companies House registration number, registered office address, primary contact details (name, email, phone), your annual turnover figure for the preceding financial year, an estimate of your total packaging tonnage for the current year, and details of your packaging activities (which producer categories apply to you).

Step 2: Access the RPD Portal

Registration is done through DEFRA's Report Packaging Data (RPD) service. You will need a Government Gateway account to access the portal. If you do not already have one, create it first at the Government Gateway registration page. The RPD portal is separate from any other DEFRA services you may use.

Step 3: Complete the Registration Form

The registration form asks for your business details, turnover bracket, estimated packaging tonnage, packaging activity types, and whether you intend to report directly or through a compliance scheme. Complete all sections accurately. Errors in registration data can cause problems with subsequent submissions and fee calculations.

Step 4: Appoint a Compliance Scheme (Optional)

Large producers can choose to manage their obligations directly or appoint an approved compliance scheme to act on their behalf. A compliance scheme handles some of the administrative burden, particularly around fee payments and liaising with the scheme administrator. If you appoint a scheme, you must still register on the RPD portal and submit your own packaging data. The scheme handles the downstream waste management obligations.

Step 5: Confirm and Submit

Review all details, confirm accuracy, and submit your registration. You should receive a confirmation email with your registration reference number. Save this — you will need it for all subsequent submissions and correspondence. Registration is typically confirmed within a few working days.

Key Deadlines

Timing matters. The reformed EPR scheme operates on a compliance year running from April to March. Key dates for the 2026-2027 compliance year include the following.

New registrations should be completed as soon as you become aware that you meet the thresholds. There is no specific registration window — you can register at any time — but registering late does not excuse you from obligations that applied during the period you should have been registered. If your business exceeded the thresholds at the start of the compliance year, you are obligated for the full year regardless of when you actually register. For a full timeline of all submission dates and milestones, see our DEFRA deadlines guide for 2026.

What Happens If You Do Not Register?

This is the part that should concentrate minds. Failing to register for EPR when your business is obligated is a regulatory offence. The consequences escalate depending on how long the non-compliance continues and how the regulator discovers it.

Discovery and Investigation

The Environment Agency (and equivalent bodies in Scotland, Wales, and Northern Ireland) have the power to investigate businesses they believe may be obligated but unregistered. They can cross-reference Companies House data, import records, industry databases, and tip-offs from competitors or supply chain partners. The scheme administrator also monitors the market for producers who appear to be operating above the thresholds without registration.

Retrospective Registration and Back-Dated Fees

If the regulator determines that your business should have been registered, you will be required to register immediately and will be liable for back-dated EPR fees covering the entire period of non-compliance. These fees are calculated based on the packaging you should have reported, and the regulator can estimate your tonnage using industry benchmarks and available supply chain data if you cannot provide accurate figures. Estimated tonnages tend to be conservative — meaning they err on the high side, which increases your fee liability.

Financial Penalties

On top of back-dated fees, the regulator can impose financial penalties. The enforcement framework includes fixed monetary penalties (up to £250 for minor breaches), variable monetary penalties (proportionate to the offence, with no statutory cap), and prosecution for the most serious or persistent offenders. A business that knowingly avoids registration to evade fees could face criminal charges.

Reputational Impact

Enforcement actions are published. Major retailers and brand owners increasingly require their supply chain partners to demonstrate EPR compliance. Being found non-compliant can damage supplier relationships, affect contract renewals, and create reputational risk with customers and investors who expect responsible environmental practices.

Reassessing Annually: When Thresholds Are Crossed

Your obligation status is not fixed forever. Businesses grow. Businesses contract. Product ranges expand or are discontinued. Import volumes fluctuate. You should reassess your turnover and packaging tonnage at the start of each compliance year.

The most common scenario is a growing business that was below the thresholds last year but has now crossed them. This happens more often than people expect. A business with £900,000 turnover that grows 15% to £1.035 million has just crossed the Small Producer turnover threshold. If their packaging tonnage also exceeds 25 tonnes, they are now obligated.

Conversely, a business that was obligated last year but has seen turnover or tonnage drop below the thresholds may become non-obligated. In this case, you should still complete any outstanding submissions for the period you were obligated, and you should notify the RPD portal of your changed status. Do not simply stop reporting without communicating the change.

Getting Started with EPR Compliance

Registration is just the beginning. Once registered, you need to collect packaging data across your entire portfolio, classify it correctly, conduct RAM assessments on household packaging, prepare DEFRA-compliant CSV files, submit on time, and manage the resulting fees. It is a substantial ongoing process, particularly in the first year when you are building your data systems from scratch.

The good news is that the process is well-defined and manageable with the right tools. Our EPR compliance checklist covers every step from registration through to audit readiness. For help understanding the full scope of UK EPR, our comprehensive UK EPR guide explains the regulatory framework in detail.

If the idea of managing all this in spreadsheets fills you with dread, Repackd was built specifically for this purpose. It automates data collection, RAM assessment, DEFRA file generation, and fee projection — turning a complex regulatory process into a manageable workflow.