Regulation guidance: Extended Producer Responsibility

Extended Producer Responsibility (EPR) is now in effect. What does it mean for those in the print industry? Sustainability consultant Rachel England outlines everything you need to know.

The Extended Producer Responsibility (EPR) scheme shifts the costs of managing household waste onto the producers of packaging. This is designed to create a more circular economy, by encouraging producers to reduce their use of packaging and take steps to make sure the packaging they do use is easier to recycle. Under EPR, producers are also expected to meet ambitious recycling targets and support consumer action through clear recyclability labelling.

In the UK, EPR is a reform of the previous UK Packaging Waste Regulations (not to be confused with the Plastic Packaging Tax) and will be introduced in a phased approach with full implementation by 2027. Since January 2025, the scheme has been overseen by a new administrator called PackUK – hosted by the UK Department for Environment Food and Rural Affairs (Defra) working on behalf of the four UK nations (and known as PecynUK in Wales).

What does EPR mean for printers?

The reporting complexities of EPR may represent a challenge for printers, largely because compliance relies on having full and granular oversight of supply chains and processes. George Atkinson, Head of Policy at EPR compliance provider Valpak, says that printers are in a unique position because it’s not always clear what packaging they are obligated to report on. 

“They’re right in in the middle of that supply chain and EPR requires data that lots of businesses don’t have centrally gathered, so it represents a real administrative burden,” he says. “And even though the government is pushing lots of information about EPR – and in my experience, knowledge of the scheme is increasing across the sector – the cost of business is increasing, so EPR is being pushed back down organisations’ agendas.”

However, it’s critical that printers take action on their obligations, especially as the first reporting deadline has now passed. “It won’t be a case of ‘no harm, no foul’,” says Atkinson. “We can expect the environment agencies to bring some sort of enforcement against those that aren’t complying, whether that’s financial penalties or full prosecutions.”

Help with EPR compliance

Given the complexities of EPR reporting, many businesses – including printers – are turning to compliance schemes for help. According to Atkinson, there are some 20 compliance schemes in the UK supporting around 97% of packaging producers with their waste disposal obligations. These schemes determine and submit reporting data and ensure that fees are paid correctly. 

Compliance schemes can also save producers money, as well as time. “Generally speaking, producers will save about 30% on the overall cost of compliance if they work with a compliance scheme,” says Atkinson.  

The upside of EPR

On the face of it, EPR appears to represent another in a long line of regulatory issues for printers, but there are long-term benefits to be had in compliance. “I can definitely understand why businesses are struggling to see is the benefits, especially if you look at the trade press headlines on EPR,” says Atkinson. “However, the scheme gives businesses an opportunity to understand their packaging in greater detail than ever before. This granularity allows you to make improvements, save money and then tell positive stories about the changes you’re making. This helps further compliance and supports you in being a more successful business both now and in the future.”

Who does EPR apply to?

The regulations apply to all UK organisations that import or supply packaging, even if packaging isn’t their central concern. 

A business will need to collect and report on its packaging data if all of the following apply: if you have an annual turnover of £1m or more, you were responsible for importing or supplying more than 25 tonnes of packaging to the UK market in the previous year, or you carry out any of the packaging activities.

How does EPR reporting work?

Organisations must report on their packaging use to determine their recycling obligation and waste management fees. Reporting requirements will depend on whether a business is a small or large organisation. 

An organisation is classified as small if either of the following apply:

• Its annual turnover is between £1m and £2m and it’s responsible for supplying or importing more than 25 tonnes of packaging in the UK  

• Its annual turnover is over £1m and it’s responsible for supplying or importing between 25 tonnes and 50 tonnes of packaging in the UK   

An organisation is classed as large if both of the following apply:

• It has an annual turnover of £2m or more   

• It’s responsible for supplying or importing more than 50 tonnes of packaging in the UK  

Small organisations must report their data yearly, while large organisations must report their data every six months. The first deadline for reporting was 1 April 2025 for both small and large organisations. Data must be reported through gov.uk’s reporting service. 

What data needs to be reported?

This is where difficulties can arise, especially for printers who frequently handle packaging in their various supply and value chains. The number of data points that need to be reported have increased four times under EPR regulations compared to previous requirements, as has the granularity of the information required. Under previous rules, only base materials needed to be reported, such as plastic, wood and so on. Under the latest EPR rules, reporting needs to be specific to format or packaging type, for example, polymers for plastic packaging. 

Any combination of packaging can contribute to meeting the 50-tonne threshold.

What about the labelling requirements of EPR?

EPR also includes provisions to make the identification of packaging material easier for end consumers. From 1 April 2026, all packaging – except flexible films – must include a binary ‘recycle’ or ‘do not recycle’ logo. Defra has licensed the Recycle Now symbols for this purpose. More information on these labelling requirements will become available closer to the 2026 deadline.

What are the fees for EPR?

The overall objective of EPR is to incentivise packaging producers to use fewer and more recyclable packaging materials, which will incur lower disposal costs than excessive use of hard-to-recycle packaging. Fees will not be payable for secondary and tertiary packaging.

Defra released indicative fees in 2024, with a range of £185-£350 per tonne of paper and board, and £335 to £600 per tonne of plastic. You will also have to pay a registration fee when you register your organisation.

Packaging fees have been deferred for one year and will start in October 2025.