Oct 31st, 2022
5 mins

The way UK organisations responsible for packaging must carry out their recycling responsibilities is changing.

If you’re affected by the new extended producer responsibility (EPR) for packaging, you will need to collect the correct packaging data from 1 January 2023.

The regulations will apply to all UK organisations that handle and supply packaging to consumers and to businesses.

Check if you need to take action:

You must take action to comply if all the following apply:

  • you’re an individual business, subsidiary or group (but not a charity)
  • you have an annual turnover of £1 million or more (based on your most recent annual accounts)
  • you’re responsible for over 25 tonnes of packaging in a calendar year (January to December)
  • you carry out any of the packaging activities


Packaging activities:

You may need to act if you do any of the following:

  • supply packaged goods to the UK market under your own brand
  • package goods for another UK organisation
  • use ‘transit packaging’ to protect goods during transport so they can be sold to UK consumers
  • import products in packaging
  • own an online marketplace
  • hire or loan out reusable packaging
  • sell empty packaging


Supplying goods to the UK market under your own brand:

Your organisation may need to take action under EPR for packaging if it sells packaged goods labelled with its own brand. A brand includes any of the following:

  • a logo
  • a trademark
  • any distinctive mark


If you package goods for another organisation, import products in packaging, own an online marketplace, hire or loan out reusable packaging (e.g. wooden pallets) or sell empty packaging, take a look at what you may need to do here.

Under the new regulations, you may need to:

  • collect and submit data on the packaging you handle and supply
  • pay a waste management fee
  • buy packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet your recycling obligations
  • submit information about where your packaging has been sold, hired, loaned, gifted or discarded – this is called ‘nation data’

What you need to do depends on whether you’re classed as a ‘small’ or ‘large’ organisation. This is based on:

  • your annual turnover
  • how much packaging you handle and supply each year


For more information about the EPR requirements, such as collecting and submitting your packaging date, click here.


If you have any questions, you can also contact the Defra packaging team:


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