UK Revises Packaging Extended Producer Responsibility (EPR) Regulation
The new Extended Producer Responsibility (EPR) for packaging was introduced in early 2025 largely in response to a 2017 report which found that, under the previous system, producers covered only around 10% of packaging waste disposal costs and exported much of their plastic waste abroad in lieu of domestic recycling investment. The new EPR will require all UK organizations that import or supply packaging to report packaging data and pay fees based on this data (flat base fees per ton of material in the year 2025 through 2026, and adjusted rates based on recyclability from then on). In the long term, the Government hopes to thus transform UK packaging into a circular economy.
U.S. businesses should be aware that the regulation affects them in the same way it affects UK businesses. Whether a business needs to take action depends on whether it fulfils all the following conditions:
- It’s an individual business, subsidiary or group (but not a charity).
- It has an annual turnover of $1.3M or more, based on its most recent annual accounts up to April 7, 2025.
- It was responsible for importing or supplying more than 25 tons of packaging to the UK market in the previous calendar year.
- It carries out any of the packaging activities.
While businesses both ‘large’ and ‘small’ must report on packaging data, the new packaging tax and the obligation to attain PRNs (Packaging Waste Recovery Notes) and PERNs (Packaging Export Recovery Notes) affect only ‘large’ organizations. Organizations are classed as ‘large’ if they have an annual turnover of $2.63M or more and supply or import more than 50 tons of packaging in the UK.
More detailed information on the specifics of EPR reporting can be found at:
Extended producer responsibility for packaging: who is affected and what to do - GOV.UK
U.S. companies have a worldwide reputation for innovative products, after sales service, and training which makes them competitive in the UK market. The U.S. and UK also share similar business cultures and business practices, which makes the UK an attractive market for U.S. suppliers.
For more information, contact Stephen Brown at Stephen.Brown@trade.gov.