EPR is a new UK policy that introduces a fundamental change to how packaging waste is regulated and who is accountable for it.
Extended Producer Responsibility (EPR) represents a complete reform of producer responsibilities with major implications for brand owners and businesses placing packaging on the UK market.
At its core, EPR is a policy approach that shifts the responsibility for the entire environmental impact of a product- from production and use, through to disposal- away from consumers and local authorities, and onto the producers themselves.
Under this legislation, businesses will be required not only to track and report data on the packaging they supply or import, but also to cover the full net cost of collecting, sorting, recycling, or disposing of it once it becomes waste, following a “polluter pays” principle.
EPR is being phased in from 2023, with full financial obligations beginning in 2025, replacing the older Packaging Waste Regulations (PWR). The goal is to drive more sustainable packaging design, increase recycling rates, and reduce the environmental burden of packaging waste by holding producers directly accountable.
Who is obligated under EPR?
Your business is likely to be affected by Extended Producer Responsibility (EPR) if it operates in the UK, is not a registered charity, has an annual UK turnover of £1 million or more, and supplies or imports over 25 tonnes of packaging into the UK each year. If you meet all of these criteria, your business is classed as an “obligated producer” under EPR. This means you must comply with new packaging data reporting requirements- and from 2025, you’ll also be responsible for covering the full cost of managing the packaging waste you place on the market.
There are two levels of obligation based on business size:
Small Producers
Turnover between £1 million and £2 million
25–50 tonnes of packaging placed on the market
Annual data reporting required
Large Producers
Turnover over £2 million
More than 50 tonnes of packaging
Biannual data reporting and full cost obligations from 2025
Expert support for brand owners navigating Extended Producer Responsibility.
Smartbox² – tailored consultancy from concept to compliance.
Navigating the complexities of EPR can be a challenge, especially for brand owners balancing regulatory, commercial, and environmental pressures. That’s where Smartbox² comes in.
At The Sherwood Group, we help you move beyond compliance - offering tailored, strategic support that simplifies EPR and enhances the sustainability and performance of your packaging.
What we offer
Full EPR audit of your packaging portfolio
We assess your packaging formats, materials, and volumes to identify where you stand under EPR. We help pinpoint areas of risk and opportunity, giving you clarity and control.
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Guidance on packaging data reporting
We offer expert guidance on what packaging data to collect and how to estimate it. While we can provide weight data support, your business remains responsible for submitting its own EPR data and payments.
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Packaging redesigns to improve recyclability and lower fees
Using Design for the Environment (DfE) principles, we redesign packaging with end-of-life impact in mind - improving recyclability, reducing materials, and helping to lower EPR fees.
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In-house design, testing, and manufacture
We manage the entire packaging process—from concept to production—under one roof. This shortens lead times and ensures consistent quality with a single, trusted partner.
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With Smartbox² you gain a competitive edge.
Our consultancy helps brand owners achieve packaging that performs environmentally, operationally, and commercially.
Register your interest in a complimentary EPR audit.
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Got questions about EPR?
Explore our FAQs below for quick, clear answers to the most common EPR queries.
RAM is Defra’s framework for assessing whether your packaging can be recycled effectively. It considers technical recyclability, available recycling infrastructure, and the potential for material reuse. Producers must carry out this assessment for household packaging and report it - these results will influence modulated fees from 2026 onwards.
From 2026, disposal fees will be modulated, meaning businesses will pay more for packaging that’s difficult to recycle and less for eco-friendly formats. This financial incentive is intended to drive better packaging design and reduce overall environmental impact.
Packaging data must be reported by volume in kilograms, but this may evolve as the scheme develops. Staying up to date with official guidance is essential.
Producers will be required to report detailed information, including:
- Producer type
- Material type (e.g. paperboard, plastic, aluminium)
- Packaging level (primary, secondary, or tertiary)
- Individual packaging components and their weight
- Nation data (where in the UK the packaging is sold/discarded)
- Disposal site information
- Waste type (required for large producers only)
This data forms the basis for calculating your financial obligations under EPR from 2025 onwards.
Under EPR, the term producer includes several types of businesses involved in placing packaging on the UK market. You may be considered a producer if you are:
- A brand owner placing packaged goods on the market under your brand
- An importer bringing packaged goods or empty packaging into the UK
- A packer or filler filling packaging with goods for sale
- A distributor supplying packaging to UK businesses
- An online marketplace enabling non-UK sellers to sell filled or empty packaging directly to UK consumers
If you carry out any of these activities and meet the turnover and packaging thresholds, you are likely obligated under EPR.