What is Extended Producer Responsibility?
Extended Producer Responsibility -- commonly abbreviated to EPR, or pEPR when referring specifically to packaging -- is a UK-wide regulatory framework that makes the businesses placing packaging on the market financially responsible for its entire end-of-life management. That means collection, sorting, recycling, and disposal.
The principle is straightforward: if you put the packaging out there, you pay for what happens to it after the consumer is done with it. The more recyclable your packaging, the less you pay. The harder it is to recycle, the more you pay. This "polluter pays" approach is designed to incentivise producers to design packaging that is easier and cheaper to manage as waste.
Why does this matter now?
The revised EPR scheme began in April 2025, replacing the previous system where producers paid only a proportion of waste management costs. Under the new regime, obligated producers cover the full net cost of managing household packaging waste. The first fee invoices will be issued in October 2026, covering the period from April 2025 to March 2026. This is not a future concern -- it is happening right now.
EPR applies across England, Wales, Scotland, and Northern Ireland, administered by the Environment Agency (EA) in England, Natural Resources Wales (NRW), the Scottish Environment Protection Agency (SEPA), and the Northern Ireland Environment Agency (NIEA). DEFRA coordinates the policy at a UK-wide level.
The scheme works through a system of data reporting and fee payments. Producers must register with the relevant environmental regulator, collect detailed data about their packaging, submit that data through the Regulated Packaging Data (RPD) portal in a specific CSV format, and then pay fees based on the volume and type of packaging they place on the market.
For the first compliance year (2025-2026), fees are calculated as flat rates per tonne of material. From the second year onwards, fees are modulated based on the Recyclability Assessment Methodology (RAM) -- meaning poorly designed packaging costs significantly more. We cover RAM ratings and fee modulation in detail in later sections.
Who is obligated?
Not every business handling packaging is caught by EPR. The regulations draw a clear line based on two criteria: annual turnover and annual tonnage of packaging placed on the UK market. You must meet both thresholds to be obligated.
| Category | Turnover Threshold | Tonnage Threshold | Reporting Frequency |
|---|---|---|---|
| Large Producer | > £2 million | > 50 tonnes | Twice per year (April & October) |
| Small Producer | > £1 million | > 25 tonnes | Once per year (April) |
Large producers carry the heavier compliance burden. They must report twice annually (for the first and second halves of each calendar year), provide RAM recyclability ratings for household packaging, and pay the full modulated fees. They cannot use the simplified "SP" (Small organisation Packaging) packaging type in their reports.
Small producers have reduced obligations. They report once per year in April, covering the full prior calendar year. They use the simplified "SP" packaging type for most of their reporting and are not required to provide RAM ratings in Year 1 -- though this is expected to change in future compliance years.
Charities: a notable exception
Registered charities are exempt from the small producer obligations, even if they meet the turnover and tonnage thresholds. However, if a charity meets the large producer thresholds, it is fully obligated. It is worth noting that charity trading subsidiaries (which are not themselves charities) can be caught regardless.
The tonnage figure refers to the total weight of all packaging you are responsible for placing on the UK market, not just what you physically handle. This includes packaging on goods you import, packaging you fill, and -- in the case of online marketplaces -- packaging on goods sold through your platform by third-party sellers.
The 6 producer types explained
Under UK packaging EPR, every obligated producer falls into one or more of six categories based on how they interact with packaging in the supply chain. These categories determine what packaging activity codes you use when submitting data to DEFRA. Many businesses will operate under multiple producer types simultaneously.
Brand Owner (Seller)
You supply packaged goods under your own UK brand. This is the most common category. If your company's name or trademark is on the packaging, you are likely a Brand Owner for EPR purposes -- even if you did not physically pack the goods.
Packer/Filler
You place goods into packaging for supply on the UK market. Contract packers and co-manufacturers typically fall here. If you fill or pack goods on behalf of another brand, this is your activity type for that packaging.
Importer
You import packaged goods into the UK from outside the country. This covers goods arriving from the EU, Asia, the Americas, or anywhere else. The importer of record is responsible for the packaging on those goods.
Supplier of Empty Packaging
You supply empty packaging to businesses that are not themselves obligated (i.e., below the turnover/tonnage thresholds). Packaging manufacturers and distributors selling to small businesses should pay close attention to this category.
Hirer/Loaner
You hire out or loan reusable packaging. This covers pallets, crates, kegs, and other transit packaging that circulates through the supply chain and is returned to you. The obligation sits with the entity that owns and circulates the packaging.
Online Marketplace
You operate a platform that facilitates the supply of packaged goods by third-party sellers. This category was introduced specifically to capture the growing volume of packaging entering the UK through e-commerce platforms where the seller may not themselves be a UK-registered producer.
A single organisation can hold multiple producer types. For example, a food manufacturer that makes products under its own brand (SO), also packs products for supermarket own-label ranges (PF), and imports ingredients in packaging from overseas suppliers (IM) would report under all three activity codes. Each row in your DEFRA submission captures a specific packaging activity and type combination.
What data you need to report
DEFRA requires producers to submit packaging data through the Regulated Packaging Data (RPD) portal in a very specific CSV file format. The file contains 15 columns, labelled A through O. Each row represents one unique combination of packaging activity, type, class, material, and nation. Here is what each column means in plain English.
| Col | Field Name | What It Means | Example |
|---|---|---|---|
| A | organisation_id |
Your unique 6-digit account number from the EPR registration portal | 123456 |
| B | subsidiary_id |
If you report as a parent company on behalf of subsidiaries, their identifier goes here. Otherwise leave blank | SUB001 |
| C | organisation_size |
Whether you are a large or small producer | L or S |
| D | submission_period |
The reporting period. Large producers use H1/H2 half-years; small producers use P0 for the full year | 2025-H1 |
| E | packaging_activity |
Your producer type for this row (how the packaging entered the market) | SO |
| F | packaging_type |
The waste stream classification (see packaging types section below) | HH |
| G | packaging_class |
The hierarchical position of the packaging (primary, secondary, etc.) | P1 |
| H | packaging_material |
The main material the packaging component is made from | PL |
| I | packaging_material_subtype |
Required for plastics (Rigid or Flexible) and "Other" materials. Blank for everything else | Rigid |
| J | from_country |
The UK nation where the packaging is placed on the market or collected | EN |
| K | to_country |
The UK nation the packaging waste is transferred to (only for waste transfer scenarios). Usually blank | |
| L | packaging_material_weight |
Total weight in kilograms. Whole numbers only, no unit labels | 5000 |
| M | packaging_material_units |
Count of individual drinks containers (only for HDC/NDC types). Blank otherwise | 12000 |
| N | transitional_packaging_units |
A legacy field. Leave blank for all 2025 submissions | |
| O | ram_rag_rating |
The RAM recyclability assessment rating. Required for large producers reporting household packaging | G |
This example row translates to: a large organisation (L), reporting for the first half of 2025 (2025-H1), acting as a brand owner (SO), for household packaging (HH) that is primary packaging (P1), made from rigid plastic (PL, Rigid), placed on the market in England (EN), weighing 5,000 kg, with a Green RAM rating (G).
Key validation rules to remember
Plastic subtypes (Rigid/Flexible) are mandatory only for HH and PB packaging types. The first letter must be capitalised -- the system is case-sensitive. Drinks containers must be between 150ml and 3 litres capacity. Weights must be whole numbers with no unit labels. Large organisations cannot use the SP type. Small organisations use only SP and HDC types.
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Try It Free →Packaging types explained
Column F in your DEFRA submission requires a packaging type code. This classifies the packaging based on the waste stream it ends up in -- essentially, where the packaging goes after the consumer is finished with it. Getting this right is critical because it determines what packaging classes are allowed, whether you need RAM ratings, and how your fees are calculated.
| Code | Name | What It Covers | Who Reports It |
|---|---|---|---|
HH |
Household | Packaging that ends up in household waste or kerbside recycling. This is the big one -- cereal boxes, milk bottles, crisp packets, shampoo bottles, etc. | Large producers |
NH |
Non-household | Packaging used in commercial, industrial, or institutional settings. Pallet wrap, bulk sacks, commercial catering packaging, office supply packaging. | Large producers |
CW |
Self-managed consumer waste | Household-type packaging that you take back and manage yourself through a compliance scheme, rather than leaving it for local authority collection. | Large producers |
OW |
Self-managed organisation waste | Non-household packaging waste that you manage through your own arrangements rather than relying on third-party waste collection. | Large producers |
PB |
Public bin | Packaging that commonly ends up in street bins, park bins, and other public litter infrastructure -- takeaway cups, snack wrappers, beverage bottles consumed on the go. | Large producers |
RU |
Reusable | Packaging designed to be refilled or reused multiple times before disposal -- kegs, reusable crates, refill containers. | Large producers |
HDC |
Household drinks containers | Drinks containers (150ml-3l) sold for household consumption. Separate reporting is required for these in preparation for a potential Deposit Return Scheme. | Both large & small |
NDC |
Non-household drinks containers | Drinks containers sold for non-household consumption -- vending machine cups, hospitality drinks, wholesale beverages. | Large producers |
SP |
Small organisation packaging | A simplified catch-all type for small producers. Covers all packaging except HDC, which small producers report separately. | Small producers only |
The most important distinction is between HH (household) and NH (non-household). Household packaging attracts the highest scrutiny and the highest fees because producers are expected to cover the full cost of local authority collection and processing. Non-household packaging typically costs less because commercial waste management is funded separately.
Packaging classes explained
Column G requires a packaging class code that describes the packaging's position in the product hierarchy. Is it the thing the consumer directly interacts with (primary), or is it the box the product ships in (shipment packaging)? Each class has specific rules about which packaging types it can be combined with.
| Code | Class Name | Description | Compatible Types |
|---|---|---|---|
P1 |
Primary packaging | The packaging in direct contact with the product that the consumer takes home. A yoghurt pot, a shampoo bottle, a crisp packet. | HH, NH, RU, SP |
P2 |
Secondary packaging | Grouping packaging used to collate multiple primary packages. A cardboard tray holding six yoghurt pots, shrink wrap around a multipack. | NH, SP |
P3 |
Shipment packaging | Packaging used to protect products during transport from manufacturer to retailer. Corrugated boxes, void fill, edge protectors. | HH, NH, SP |
P4 |
Tertiary packaging | Large-scale transit packaging. Pallets, pallet wrap, strapping, bulk containers used to move goods through the supply chain. | NH, SP |
P5 |
Non-primary reusable | Reusable packaging that is not the primary pack. Returnable transit packaging like reusable crates, dollies, and intermediate bulk containers. | RU |
P6 |
Online marketplace total | Used by online marketplaces (OM activity) to report the total packaging placed on the market by third-party sellers on their platform. | HH, NH, SP |
O1 |
Self-managed consumer waste (all) | The only class allowed for CW (self-managed consumer waste) packaging type. | CW only |
O2 |
Organisation waste origin | The only class allowed for OW (self-managed organisation waste) packaging type. | OW only |
B1 |
Public bin | The only class allowed for PB (public bin) packaging type. | PB only |
Watch the compatibility rules
Not every class works with every type. For example, primary packaging (P1) can be classified as HH or NH but not as PB. Public bin packaging must always use B1. Drinks containers (HDC/NDC) do not use a class code at all -- leave column G blank. Getting these wrong will cause your CSV file to fail validation on the RPD portal.
Material codes
Column H identifies the material your packaging component is made from. DEFRA uses eight top-level material codes. For most materials, the code alone is sufficient. Plastics and "Other" materials require an additional subtype in column I.
| Code | Material | Examples | Subtype Required? |
|---|---|---|---|
AL |
Aluminium | Drinks cans, foil trays, aerosol cans, foil lids, blister packs | No |
FC |
Fibre composite | Tetra Pak-style cartons, Pringles tubes, paper cups with plastic lining | No |
GL |
Glass | Bottles, jars, vials, cosmetic containers | No |
PC |
Paper or card | Cardboard boxes, paper bags, corrugated shipping cases, paper labels, tissue wrapping | No |
PL |
Plastic | PET bottles, HDPE containers, PP tubs, LDPE film, polystyrene trays | Yes: Rigid or Flexible (for HH and PB types) |
ST |
Steel | Food cans, paint tins, biscuit tins, steel drums, steel strapping | No |
WD |
Wood | Wooden pallets, crates, wine boxes, produce punnets, wooden lids | No |
OT |
Other | Any material not covered above | Yes: material name (e.g., bamboo, ceramic, copper, cork, hemp, rubber, silicone) |
The most common point of confusion is plastic subtypes. When reporting plastics for household (HH) or public bin (PB) packaging types, you must specify whether the plastic is Rigid (bottles, tubs, trays, pots) or Flexible (films, pouches, bags, wrappers). The system is case-sensitive: Rigid with a capital R, Flexible with a capital F. For non-household plastics, the subtype is not required.
For drinks containers specifically, only four materials are accepted: aluminium (AL), glass (GL), plastic (PL -- PET only), and steel (ST). If your drinks container is made from anything else, it may not qualify as a drinks container under the regulations.
Multi-material packaging
If a packaging component is made from multiple materials (for example, a paper cup with a plastic lining), you should report it under the material that makes up the majority of its weight. Where the materials cannot be separated, the whole component is reported as a single material -- typically fibre composite (FC) for lined cartons. If materials are separable (like a glass jar with a metal lid), report each component as a separate row.
Key deadlines for 2025-2026
Missing an EPR deadline is not just inconvenient -- it can trigger enforcement action and financial penalties. Here are all the key dates obligated producers need to know.
Do not miss April 2026
The 1 April 2026 deadline is the next major submission date and is particularly important. It is the first time small producers must submit data, and it is the second submission for large producers. Late or inaccurate submissions may result in enforcement action, including civil penalties of up to £100,000.
Never miss a DEFRA deadline
Repackd tracks every submission window, sends automated reminders, and generates your RPD file in one click when the time comes. Set it and forget it.
Start Free Trial →Fee structure and modulation
The financial sting of EPR comes in the form of fees that producers must pay to cover the cost of managing their packaging waste. These fees are calculated per tonne of material and are invoiced annually by the Environment Agency.
Year 1: Flat fees (2025-2026)
For the first compliance year, fees are calculated as simple flat rates per tonne, based on the average cost of collecting, sorting, and recycling each material type. There is no modulation based on recyclability in Year 1 -- all packaging of the same material pays the same rate per tonne, regardless of how well-designed it is.
This gives producers a grace period to get their data collection processes in order and start working towards better recyclability ratings before modulation kicks in.
Year 2 onwards: Modulated fees based on RAM
From the 2026-2027 compliance year, fees are modulated according to the Recyclability Assessment Methodology (RAM) rating. Packaging that is easy to recycle (Green-rated) pays less. Packaging that is difficult or impossible to recycle (Red-rated) pays more. The gap widens every year.
| Compliance Year | Modulation Factor (Red vs Green) | What This Means |
|---|---|---|
| 2025-2026 | None (flat fees) | All packaging of the same material pays the same rate. RAM ratings are collected but do not affect fees |
| 2026-2027 | 1.2x | Red-rated packaging pays 20% more than Green-rated. The first year where your RAM rating directly impacts your bill |
| 2027-2028 | 1.6x | Red-rated packaging now pays 60% more. The gap is widening and the financial pressure to redesign is mounting |
| 2028-2029 | 2.0x | Red-rated packaging pays double the base rate. Green-rated packaging benefits from the lowest fees. The system has reached full modulation |
How RAM ratings work
The RAM assesses recyclability of household packaging across five stages, based on actual UK recycling infrastructure (not theoretical potential):
- Classification -- Can the material type and format be identified?
- Collection -- Is there UK kerbside or bring-site collection infrastructure for this material?
- Sortation -- Can existing Materials Recovery Facilities (MRFs) mechanically separate this material from the mixed waste stream?
- Reprocessing -- Can the sorted material be converted into a new raw material or product?
- Application -- Is there a viable end-market for the recycled output?
Packaging must pass all five stages to achieve a Green rating. Failing at any stage results in an Amber or Red rating depending on the severity. Common reasons for poor ratings include: multi-material components that cannot be separated, black plastic that optical sorters cannot detect, non-standard polymer blends, excessive adhesive coverage, and contamination from inks or coatings.
The RAM was updated to version 1.1 in April 2025, which streamlined additive weight thresholds, updated label coverage specifications, revised adhesive composition limits, and introduced recognition for take-back schemes accessible to 75% or more of the UK population.
The financial case for going Green
Consider a producer placing 200 tonnes of household plastic packaging on the market. If the base fee is £300 per tonne, a Green rating at full modulation could mean paying £30,000, while a Red rating would cost £60,000 -- a difference of £30,000 per year for a single product line. Multiply that across your full portfolio and the savings from improved packaging design become substantial.
Penalties for non-compliance
The UK environmental regulators have enforcement powers to ensure compliance with packaging EPR obligations. Non-compliance can be costly, both financially and reputationally.
Civil penalties
The Environment Agency (and equivalent bodies in Scotland, Wales, and Northern Ireland) can issue civil penalties of up to £100,000 for:
- Failure to register as an obligated producer
- Late submission of packaging data
- Submission of inaccurate or incomplete data
- Failure to pay EPR fees by the due date
- Failure to comply with an information notice or enforcement notice
Criminal prosecution
For persistent or deliberate non-compliance, the regulators can pursue criminal prosecution. This can result in unlimited fines. Additionally, company directors can be held personally liable for offences committed with their consent, connivance, or through their negligence.
Reputational risk
Beyond the direct financial penalties, non-compliance carries significant reputational risk. Enforcement actions are published by the regulators. In an era where consumers, investors, and business partners increasingly scrutinise environmental credentials, a public enforcement action for packaging non-compliance can damage trust and brand value far in excess of the fine itself.
The cost of inaction
Some businesses are delaying EPR compliance, hoping the regulations will be watered down or delayed. This is a risky strategy. The first fee invoices are being issued in October 2026, based on data that should already have been submitted. Businesses that have not registered or reported face immediate enforcement exposure -- and a scramble to retrospectively collect the data they should have been gathering since April 2025.
How Repackd helps
If you have read this far, you understand that UK packaging EPR is not trivial. The data requirements are detailed, the deadlines are rigid, and the financial consequences of getting it wrong are serious. This is exactly the problem Repackd was built to solve.
One-click DEFRA reports
Repackd generates submission-ready RPD CSV files in the exact format DEFRA requires. All 15 columns, correct activity codes, type codes, class codes, material codes, and nation allocations -- validated against every rule before you download. One click. Done. No more hand-coding CSV files or worrying about case-sensitivity on plastic subtypes.
Instant RAM scoring
Upload your packaging specifications and get Red, Amber, or Green ratings in seconds. Our assessment engine evaluates all five RAM stages automatically, based on actual UK recycling infrastructure data. No consultants, no waiting, no ambiguity about where your packaging stands.
Smart data collection
Upload packaging specs, technical drawings, or supplier datasheets. Repackd extracts material type, weight, dimensions, and bill of materials data automatically. Or invite your suppliers to our self-service portal where they enter data through guided forms with real-time validation. The data flows straight into your dashboard, verified and ready.
Fee optimisation
See exactly how much your packaging portfolio costs in EPR fees. Then simulate material changes -- switch from multi-layer to mono-material, replace black plastic with a detectable alternative, change from flexible to rigid -- and instantly see the impact on your RAM rating and your EPR bill. With fee modulation escalating to 2x by 2028-2029, the savings from better packaging design compound every year.
Deadline management
Repackd tracks every EPR submission window and sends automated reminders well before each deadline. When the time comes, your data is already validated and your report is ready to generate. No last-minute panic, no missed submissions, no enforcement risk.
Ready to simplify your EPR compliance?
Join 2,800+ producers who use Repackd. 14-day free trial, no credit card required. From signup to DEFRA submission in the same afternoon.
Frequently asked questions
EPR is a UK-wide regulatory scheme requiring producers who place packaging on the market to cover the full cost of managing that packaging once it becomes waste. This includes collection, sorting, recycling, and disposal costs. The revised scheme began in April 2025, replacing the previous system where producers paid only a proportion of these costs.
You are obligated if your business has annual turnover exceeding £1 million AND handles more than 25 tonnes of packaging per year on the UK market. Businesses exceeding £2 million turnover and 50 tonnes are classified as large producers with additional reporting requirements. You must meet both the turnover and tonnage thresholds to be obligated. Charities are exempt from small producer obligations but not from large producer obligations.
1 April 2025: Registration for all producers. 1 October 2025: Large producers submit H1 2025 data plus RAM ratings. 1 April 2026: Small producers submit their full 2025 data, and large producers submit H2 2025 data. October 2026: First fee invoices issued, covering April 2025 to March 2026. Large producers then submit H1 2026 data in October 2026.
RAM (Recyclability Assessment Methodology) is a standardised framework that assesses how recyclable your packaging is in practice, based on actual UK infrastructure. Packaging is rated Red (not recyclable), Amber (partially), or Green (fully recyclable) across five assessment stages. From the 2026-2027 compliance year, your RAM rating directly affects your fees. By 2028-2029, Red-rated packaging will cost 2x the base rate, while Green-rated packaging enjoys reduced fees. Getting a better RAM rating is one of the most impactful things you can do to reduce your EPR costs.
DEFRA requires a CSV file with exactly 15 columns (A through O), covering: organisation ID, subsidiary ID, organisation size, submission period, packaging activity, packaging type, packaging class, material, material subtype, from country, to country, weight in kg, material units (drinks containers), transitional units (blank), and RAM RAG rating. Each row represents one unique combination of activity, type, class, material, and nation. The file must start with a header row, contain no blank rows, and comply with strict validation rules for each field.
The Environment Agency can issue civil penalties of up to £100,000 for failure to register, late data submission, inaccurate reporting, or non-payment of fees. Criminal prosecution can result in unlimited fines, and directors can be held personally liable for offences committed with their consent or negligence. Enforcement actions are also published, carrying significant reputational risk.
In Year 1 (2025-2026), small producers are not required to provide RAM ratings. They use the simplified SP packaging type for most reporting and only need to report HDC (household drinks containers) separately. However, this is expected to change in future compliance years as the scheme matures. Small producers should be preparing to assess their packaging recyclability even if it is not yet mandatory.
Yes. Many businesses operate under multiple producer types simultaneously. A food manufacturer might be a Brand Owner (SO) for own-brand products, a Packer/Filler (PF) for products they pack on behalf of other brands, and an Importer (IM) for ingredients they bring in from overseas. Each packaging activity is reported as a separate row in your DEFRA submission using the relevant activity code.
Costs depend on the volume, material type, and recyclability of your packaging. For Year 1 (2025-2026), fees are flat rates per tonne of material. From Year 2, fees are modulated by RAM rating -- Red-rated packaging progressively costs more (up to 2x by 2028-2029), while Green-rated packaging costs less. The total bill for a mid-market producer placing hundreds of tonnes on the market could range from tens of thousands to hundreds of thousands of pounds annually. Repackd's fee optimisation engine can model your exact costs and show you how to reduce them.
Household (HH) packaging is packaging that ends up in the household waste stream -- collected by local authorities through kerbside recycling or general waste bins. This includes consumer products like food packaging, toiletries, cleaning products, and beverages. Non-household (NH) packaging is used in commercial, industrial, or institutional settings -- pallet wrap, bulk containers, commercial catering packaging. The distinction matters because producers must cover the full cost of household packaging waste management, making HH fees typically higher than NH fees.