EPR for Small Producers: Everything You Need to Know

If you run a small or mid-sized business that handles packaging in the UK, there is a good chance you have heard about Extended Producer Responsibility — and an equally good chance you are unsure whether it applies to you. The reformed UK EPR scheme that launched in April 2025 deliberately created a separate category for smaller businesses: the Small Producer. This category comes with different thresholds, simplified reporting requirements, and lower initial compliance costs. But it is still a legal obligation, and the requirements are set to ramp up significantly over the coming years.

This guide covers everything a small producer needs to know: how to determine if you qualify, what you need to report, how your obligations differ from large producers, what it will cost, and how to prepare for the tightening requirements that are already on the horizon.

What Defines a Small Producer?

Under the reformed EPR regulations, a small producer is a business that meets both of the following criteria:

• Annual turnover greater than £1 million but not exceeding £2 million
• Annual packaging handled greater than 25 tonnes but not exceeding 50 tonnes

Both conditions must be met. A business with £1.5 million turnover but only 20 tonnes of packaging is below the tonnage threshold and is not obligated at all. A business with £800,000 turnover but 40 tonnes of packaging is below the turnover threshold and is also not obligated. Both gates must be cleared.

Importantly, if your business exceeds either of the large producer thresholds (£2 million turnover or 50 tonnes packaging), you are classified as a large producer regardless of the other figure. There is no choosing which category suits you better. The classification is determined by your numbers.

The “Borderline” Problem

Many small businesses sit close to the thresholds and move in and out of obligation from year to year. A business with £1.1 million turnover and 27 tonnes of packaging is a small producer. If turnover dips to £950,000 next year, they are no longer obligated. If a strong year pushes turnover to £2.2 million, they become a large producer with significantly more onerous obligations.

This creates a real practical problem. You need to reassess your status every year, and you need to be prepared to step up your compliance systems at relatively short notice. The businesses that handle this well are the ones that track their packaging tonnage and turnover throughout the year rather than finding out in March that they have crossed a threshold.

How Small Producer Reporting Differs from Large Producers

The reformed EPR scheme deliberately gives small producers a lighter compliance burden. Here are the key differences.

Reporting Frequency

Large producers must submit packaging data twice per year: an H1 submission covering April to September (due in October) and an H2 submission covering October to March (due in April). Small producers submit once per year: an annual submission covering the full April-to-March compliance year, due in April.

This is a significant practical advantage. It means one data collection exercise per year, one submission process, one sign-off, and one period of intense compliance activity. For a small business with limited staff, this makes EPR manageable rather than a constant background obligation.

Data Requirements

Both large and small producers must submit data in the DEFRA RPD 15-column CSV format. The columns are the same: organisation, subsidiary, brand, packaging activity, packaging type, packaging class, material type, material subtype, from-nation, to-nation, quantity in units, quantity in tonnes, total weight, RAM rating, and producer size. However, the level of granularity expected from small producers is less demanding in practice.

Small producers still need to report every distinct packaging component, but DEFRA's compliance approach acknowledges that smaller businesses may not have the same level of packaging specification data that large producers maintain. There is more tolerance for estimated weights (provided the estimates are reasonable and documented) and less expectation of component-level precision for multi-component packaging items.

That said, the data must still be accurate and defensible. “Simplified” does not mean “approximate.” If your data is significantly wrong, you face the same enforcement risks as a large producer.

RAM Assessment Requirements

This is where the small producer advantage is most significant — at least for now. In the initial years of the reformed scheme, small producers are not required to conduct full RAM assessments on their packaging. They can report RAM ratings as “Not Applicable” or use a default rating without going through the five-stage assessment process.

This was a deliberate policy decision by DEFRA. Conducting proper RAM assessments requires detailed knowledge of packaging materials, formats, sortation processes, and end-market applications. Expecting small businesses to develop this expertise immediately was considered disproportionate. Instead, the requirement is being phased in gradually.

Fee Modulation

The fee modulation framework applies differently to small producers in the early years. Because RAM ratings are not mandatory for small producers yet, the modulation multipliers (which adjust fees based on packaging recyclability) are being applied at a reduced rate or with default assumptions. This means small producers are currently paying a more standardised fee per tonne rather than the differentiated fees that large producers face based on their specific RAM ratings.

When RAM reporting becomes mandatory for small producers, they will be subject to the same modulation framework as large producers. At that point, the recyclability of your packaging will directly determine your costs. This is another reason to start assessing your packaging now — you want to know your fee exposure before it hits.

What Small Producers Actually Need to Do

Let us be practical. Here is exactly what a small producer needs to do to comply with EPR obligations in the 2026-2027 compliance year.

1. Register on the RPD Portal

If you have not already registered, do so immediately. Access the DEFRA Report Packaging Data (RPD) service through your Government Gateway account. Complete the registration form with your business details, turnover, estimated tonnage, and packaging activity types. If you already registered for the 2025-2026 year, check that your details are still current. For a full step-by-step, see our EPR registration guide.

2. Identify All Your Packaging

Map every packaging component your business handles. This includes:

• Primary packaging: The immediate container for the product (bottles, jars, tubes, bags, trays, boxes that the consumer takes home)
• Secondary packaging: Packaging that groups multiple primary units together (multipacks, outer sleeves, display cartons)
• Transit packaging: Packaging used to protect products during transport (shipping boxes, pallet wrap, void fill, edge protectors)
• Imported packaging: Packaging on any goods you import from outside the UK, even if you did not specify or design that packaging

For each component, you need to know: what material it is made from (plastic, paper/card, glass, aluminium, steel, wood), its weight, and whether it is household packaging (reaches the consumer at home) or non-household packaging (stays in the commercial/industrial chain).

3. Weigh Your Packaging

You need weight data for every packaging component, measured in tonnes. For many small producers, this is the most time-consuming part of the process. You can use supplier data sheets for component weights, but it is good practice to verify with your own measurements. Weigh at least three samples of each component and use the average. For imported goods, use customs declarations and packing lists to establish packaging weights.

Calculate your total annual tonnage by multiplying the unit weight of each component by the number of units placed on the UK market during the compliance year.

4. Classify Your Packaging Correctly

Every component must be classified by packaging type (household, non-household, public bin, transit), packaging class (primary, secondary, shipment, transit), and material type and subtype. The classification determines which fee rates apply and what downstream waste management obligations are associated with your packaging.

Getting the household/non-household classification right is particularly important. Household packaging attracts the full EPR fee because the cost of collecting and processing it from households is borne by the system. Non-household packaging has lower fees because businesses typically manage their own waste collection. If you misclassify household packaging as non-household, you are under-paying fees and facing a compliance risk.

5. Prepare and Submit Your CSV File

Format your data as a 15-column CSV file matching DEFRA's template specification. Submit through the RPD portal before the April deadline. A senior officer of your company must sign off on the accuracy of the data. For the 2026-2027 compliance year, the annual submission deadline is April 2027.

Save a copy of everything: the submitted file, the portal confirmation, and all supporting documentation. You need to keep records for at least seven years.

Cost Implications for Small Producers

One of the most common questions from small producers is: how much is this going to cost? The answer depends on your packaging volume, material types, and how the fee structure evolves. Here is a framework for thinking about it.

Direct Fees

EPR fees are calculated per tonne of household packaging placed on the UK market, broken down by material type. The fee rates are set annually by DEFRA. As a rough guide for 2026-2027, expect base rates in the range of £100 to £400 per tonne depending on material, with plastic at the higher end and paper/card at the lower end.

For a small producer handling 30 tonnes of mixed packaging with roughly half being household packaging, the annual fee might be in the range of £2,000 to £6,000. This is a very rough estimate — your actual figure depends on your specific material mix and the final fee rates published by DEFRA.

Compliance Costs

Beyond the direct fees, there are costs associated with managing compliance: staff time for data collection, data management tools, and potentially professional advice for complex situations. For a small producer doing this in-house, expect to spend 2-5 days per year on the data collection and submission process. If you are using spreadsheets, it will take longer and carry more risk of errors.

Fee Trajectory

The fee trajectory for small producers is upward. As RAM requirements become mandatory and fee modulation applies fully, small producers with poorly recyclable packaging will see their fees increase. The modulation multiplier for Red-rated packaging reaches 2.0x by the 2028-2029 compliance year, meaning a component that would cost £200 per tonne at the base rate would cost £400 per tonne if it receives a Red RAM rating.

The message is clear: the cost of non-recyclable packaging is going up significantly. Small producers who act early to understand and improve their packaging recyclability will pay less over the coming years than those who wait.

Common Small Producer Scenarios

To make this concrete, here are some typical small producer situations and how EPR applies to each.

The Online Retailer

You sell products online with £1.3 million turnover. You import goods from overseas (25 tonnes of packaging on imported products) and ship them in your own branded boxes and mailers (8 tonnes). Total packaging: 33 tonnes. You are a small producer. You need to report on both the imported packaging and your own shipping packaging. The imported packaging is particularly important — many online retailers forget that the packaging on goods they import counts as their obligation.

The Food and Drink Producer

You make artisan sauces and condiments with £1.6 million turnover. Your products go into glass jars with metal lids and paper labels (18 tonnes), packed in cardboard cases (5 tonnes), and shipped on pallets with stretch wrap (4 tonnes). Total: 27 tonnes. You are a small producer. Your household packaging (the jars, lids, and labels that the consumer takes home) attracts full EPR fees. Your transit packaging (cases, pallets, wrap) is non-household and has lower fees.

The Contract Packer

You provide contract packing services with £1.8 million turnover. You handle 45 tonnes of packaging per year, but the brand owners you pack for are large producers who report their own packaging. In this case, the packaging you fill on behalf of registered brand owners is reported by them, not by you. Only the packaging you handle for brands that are not registered (for example, small brands below the thresholds) and your own business packaging counts towards your obligation. Carefully assess which packaging is genuinely yours to report.

The Importer-Distributor

You import and distribute consumer electronics with £1.9 million turnover. The products arrive in manufacturer packaging (30 tonnes) and you add no additional packaging. All 30 tonnes are your obligation because you are the importer. You are a small producer. Every box, blister pack, plastic bag, foam insert, and manual booklet wrapper counts. Collect packaging specifications from your overseas suppliers — this is often the hardest part for importers.

Preparing for the Requirements That Are Coming

The small producer category was designed as a transitional step. DEFRA's intention is that over time, the requirements for small producers will converge with those for large producers. Here is what you should be doing now to prepare.

Start Voluntary RAM Assessment

Even though RAM ratings are not yet mandatory for small producers, begin assessing your packaging now. This gives you time to understand the methodology, identify problematic components, and explore alternatives before you are under time pressure. Use the DEFRA material profiles to evaluate each component against the five RAM stages. Our UK EPR guide explains the RAM methodology in detail.

Build Good Data Habits

The businesses that struggle most with EPR are the ones that treat it as an annual fire drill rather than an ongoing process. Set up a system to track packaging changes throughout the year. When you introduce a new product, change a supplier, or modify a packaging specification, update your packaging register immediately. When the annual submission deadline arrives, your data should already be 90% complete.

Engage Your Suppliers

Request material specifications, component weights, and composition data from your packaging suppliers. If you import goods, ask your overseas suppliers for packaging specifications. This data is essential for accurate reporting and will become even more important when RAM assessments become mandatory. Build the request into your procurement process now so it becomes routine.

Consider Your Packaging Choices

Every packaging decision you make today has a fee consequence that will become more pronounced as modulation escalates. When specifying new packaging or reviewing existing specifications, consider recyclability alongside cost, functionality, and brand presentation. Switching from a non-recyclable material to a recyclable one now avoids higher fees later and reduces the compliance burden when RAM reporting kicks in.

Invest in the Right Tools

Spreadsheets work for the first year. They become painful in the second year and unsustainable by the third, especially as data requirements increase. A dedicated compliance platform like Repackd is designed to handle the data management, RAM assessment, and DEFRA file generation that makes up the bulk of the compliance workload. The investment pays for itself in time savings and error reduction.

Growing Into a Large Producer

If your business is growing, there is a good chance you will cross the large producer thresholds (£2M turnover and 50T packaging) within a few years. When that happens, your obligations increase substantially: twice-yearly submissions, mandatory RAM assessments, full fee modulation, and more detailed data requirements.

The transition is much smoother if you have been running a proper compliance process as a small producer rather than doing the bare minimum. All the data habits, supplier relationships, and packaging knowledge you build now transfer directly to the large producer obligations. Think of your small producer compliance as training for the full event.

Frequently Asked Questions

What if my turnover is over £2M but my tonnage is under 50 tonnes?

If your tonnage is between 25 and 50 tonnes, you are still a small producer. The small producer category applies when tonnage is 25-50T and turnover is £1-2M. However, if your turnover is over £2M, you need to check the tonnage threshold carefully. If your tonnage is also over 50T, you are a large producer. If your tonnage is between 25-50T with turnover over £2M, you may still be classified as large — consult the specific regulations or seek advice.

Do I need a compliance scheme as a small producer?

No. Small producers can manage their obligations directly by reporting through the RPD portal and paying fees to the scheme administrator. Appointing a compliance scheme is optional and typically more relevant for large producers with complex portfolios. However, some small producers find that a scheme simplifies the administrative process, particularly around fee payments.

What records do I need to keep?

Keep records of all packaging data, weight measurements, supplier specifications, submission confirmations, and fee payments for a minimum of seven years. Organise by compliance year. These records are your defence in the event of a regulatory audit.

Can I be penalised as a small producer?

Yes. The enforcement framework applies equally to all obligated producers regardless of size. Late submissions, inaccurate data, and failure to register when obligated all carry the same penalty risks for small producers as for large ones. The regulators have been clear that size is not a mitigating factor for non-compliance.