The extended producer responsibility (EPR) is an environmental policy based on the ‘polluter pays’ principle and shifts the cost of waste and recycling of packaging from local authorities to the producer. Ultimately, the goal is to incentivise them to use more environmentally-friendly packaging and reduce the total amount of waste from UK businesses.
The policy also lets local authorities recover their costs by collecting packaging fees from producers.
The fees will be based on the amount and type of packaging entering the UK market. Generally, the less environmentally friendly the packaging, the higher the rate per tonne. It's imperative that CFOs understand if their organisation is liable as soon as possible to avoid misunderstandings that lead to mistakes and unnecessary fees.
Are you a manufacturer, retailer, online platform, or wholesale importer/distributor of packaging or packaged goods?
If so, it’s likely that it does apply to your business. These are the specific requirements:
Firstly, it means you need to collect and report packaging data. Secondly, it means you may be liable to pay EPR packaging fees in October 2025. Now is the time to act because the data needed to meet reporting requirements and calculate your fee is likely to be significantly more detailed than what you may have previously reported under similar packaging regulations.
EPR will surprise some organisations. Here are three of the most likely mistakes CFOs need to be aware of.
Understanding who is responsible is not always straightforward. For example, if a UK food company manufactures goods under their own brand – they're responsible. However, if the goods are produced and packaged under the supermarket’s brand, the supermarket is responsible. Or consider these examples: you may need to take action if you hire out reusable packaging, like a wooden pallet. You may also need to take action if you sell imported goods that are packaged on behalf of a company that isn't established in the UK. So, it's worth spending time understanding which role you play in your supply chain.
For UK businesses with limited global presence, EPR may feel unfamiliar. Because it could feel similar to plastic packaging tax (PPT), it’s easy to assume EPR refers only to plastic. That’s not correct. EPR applies to all types of material, from aluminium, glass, and steel to wood, bamboo, and ceramic. The scope of EPR is wide – and will apply to a broad range of businesses.
With EPR, there are plenty of items you may not think need reporting, but which do constitute packaging, and there aren’t as many exceptions as you would think. Examples of obligated items include frames used within freight containers, pallets, barrels and kegs, gas cylinders, disposable cups, artificial haggis skins, inhaler cartridges, mascara brushes, razor blade holders, sterile medical packaging, and glass vials containing medicines. If you’re dealing with these items, EPR may apply to you.
With the first producer invoices being issued in October 2025, now is the time for finance teams to start preparing for them. Here are two key actions:
For more insight and guidance on the extended producer responsibility contact Oliver Bridge or Daniel Rice.
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