The UK government has made significant updates to the packaging Extended Producer Responsibility (EPR) Regulations, impacting how businesses handle packaging waste. These changes aim to enhance recycling efforts, reduce landfill waste, and promote sustainable practices.

Amongst the many changes within the updated EPR regulations, we would like to remind companies of the introduction of a lower threshold now used to determine producer’s legal obligations.

Here’s what you need to know:

Thresholds Overview:

  • The EPR system now distinguishes between Small Producers and Large Producers based on specific criteria.
  • Both categories have different turnover and packaging handling thresholds.
    • A Small Producer is defined as a business that:
      • Has an annual turnover of £1 million or more.
      • Handles at least 25 tonnes of packaging in the previous calendar year.
      • Is not above both of the higher thresholds (explained below).
    • A Large Producer meets the following criteria:
      • Has an annual turnover of £2 million or more (based on the last financial year’s accounts).
      • Handles more than 50 tonnes of packaging each year.
  • Physical Presence Requirement:
    • In addition to turnover and packaging volumes, businesses must also have a physical presence in the UK to be obligated under the EPR system.

Implications for Businesses

  1. New Legal Requirements:
    • The inclusion of Small Producer thresholds means that companies previously not obligated under the previous Packaging Regulations may now have legal responsibilities.
    • If your business meets the criteria for Small Producers, you must comply with the EPR rules.
  2. Awareness and Compliance:
    • If you’re selling goods into the UK and are not currently registered, it’s essential to assess whether you fall under the Small or Large Producer category.

For help verifying your obligations, or support with other environmental compliance topics, please reach out to for guidance.

Published: May 14, 2024