Extended Producer Responsibility (EPR) for Packaging — What It Means and Why It Matters

By John Elliot

Published Oct 2025

What It Means and Why It Matters

EPR is a major change in UK packaging law designed to increase recycling and reduce waste. It moves us toward a circular economy — where materials are reused and recycled rather than thrown away.

At present, recycling systems vary widely between councils, causing confusion for households and businesses. The new Simpler Recycling initiative will standardise what can be recycled across England, making it easier for everyone to do the right thing. This consistency will help boost recycling rates, reduce contamination, and ensure food waste is diverted to more sustainable processes such as anaerobic digestion.

A New “Polluter Pays” Approach

EPR shifts responsibility for the cost of collecting and recycling packaging from local authorities to the producers — usually the brand owners. This means the companies that create packaging must now fund its end-of-life management.

The goal is to encourage producers to design more recyclable packaging, cut waste, and invest in sustainable materials. Nationally, this will cost the UK packaging supply chain around £1.5 billion — a substantial shift in responsibility. The money raised will be reinvested into improving recycling infrastructure. To ensure accountability, local authorities must demonstrate that these funds are spent on developing recycling systems, not absorbed into general budgets.

Who Does It Affect?

Small Organisations

You are classed as a small producer if:

• Your annual turnover is £1–2 million, and
• You supply or import 25–50 tonnes of packaging into the UK per year.

Large Organisations

You are classed as large if:

• Your annual turnover is £2 million or more, and
• You supply or import over 50 tonnes of packaging annually.

Packaging covers any material used to protect, contain, or transport goods — from delivery boxes to takeaway cups.

What Businesses Must Do

All affected organisations must:

• Report the weight and type of all packaging used — primary, secondary, and tertiary.
• Include details of shipping and e-commerce packaging sent to customers.
• Assess recyclability using the Recycling Assessment Methodology (RAM), which rates materials as:
  • Red – difficult to recycle
  • Amber – recyclable but needs specialist facilities
  • Green – widely recyclable

This level of data collection can be challenging, especially for smaller businesses unfamiliar with packaging specifications.

Auditel can help simplify this process. Our partners software can automatically extract packaging data from your systems, ensuring it’s in the correct format for submission — saving time, reducing admin, and helping you stay compliant.

When and How to Report

Producers must submit packaging data via DEFRA’s Report Packaging Data (RPD) service.

• Large organisations will report data for 1 July–31 December 2025, with a submission deadline of 1 April 2026.
• From 2026–27, EPR fees will vary (“modulated”) based on recyclability — less recyclable materials will cost more.

Base Fees (2025)

Producers using non-recyclable materials could see higher costs once modulated fees take effect.

Reducing Your Costs

Most companies (about 95%) use third-party compliance scheme services to handle EPR reporting. This is an additional cost — although you can do it yourself by following the guidelines on the Defra website.

Or:

• Use Auditel’s Data Solutions — We work in partnership with a specialist UK software provider to implement, a data management system designed for EPR and Plastic Packaging Tax reporting, to capture and format your packaging data automatically for submission.
• Review Your Packaging Design — Auditel can perform an ISO 18602 Packaging Optimisation Review, evaluating materials, logistics, and recyclability to minimise costs and environmental impact.

In Summary

EPR represents a major shift — holding producers accountable for packaging waste. While it adds new reporting duties, it also brings opportunities to:

• Improve sustainability,
• Cut costs through smarter packaging choices, and
• Strengthen your brand’s environmental credentials.

Auditel can support you every step of the way — from data collection and compliance to full packaging optimisation — making EPR compliance straightforward and cost-effective.