Does your business fall under the Packaging Regulations?

Everyone knows the drive is on to reduce waste, specifically packaging waste. So over the years packaging regulations and charges have been introduced for single-use carrier bags to reduce number ending up in landfill. The Plastic Packaging Tax was introduced a couple of years ago to tax businesses who used plastic packaging with less than 30% recycled content. For nearly 30 years businesses have had to pay for packaging they have a handled. “Handled” in this context means:

Packaging arriving around imported goods.
Packaging used for putting product into.
Packaging that is sold on to consumers who remove the packaging and place it into the waste stream.

Although a lot has been happening over the years, there is no let up, and in 2024 the reach of charges was extended from solely applying to ‘large’ businesses to cover small businesses also. A review of the packaging regulations gave rise to the Extended Producer Responsibility Regulations (EPR). The table below sets out the thresholds for when “Extended Producer Responsibility” applies to businesses. There are two elements: –

Turnover; and
Tonnage of packaging imported or supplied in any calendar year.

Turnover is straightforward. But we have found that what constitutes ‘packaging’ can take companies by surprise. So below are some key aspects to include when working out your annual tonnage figure.

What constitutes Packaging?

Packaging is anything used to contain, protect, handle, deliver or present raw materials and/or processed/finished goods.

This means that transit packaging needs to be included in your figures. Including: pallets and shrink wrap, corrugated fibre board, polypropylene strapping, etc.
Plant pots may be classed as packaging as they are used to protect and transport the plant/flower.
Display trollies for goods (e.g. milk) need to be included alongside caps / closures and labels.

So, it’s not just the bubble wrap around a finished good or the plastic containers. The tonnage needs to encompass a far wider listing of items.

The Obligations and Deadlines

Most ‘Large Producers’ have been aware of their obligations for several years. Thus, have been making their annual returns through their chosen ‘compliance scheme’ and paying the charges accordingly.

However, for many businesses who now fall into the ‘small producer’ category, the obligations for registration, record keeping, data returns and deadlines can be confusing.

We’re approaching data return deadlines. So we thought it helpful to remind businesses of these to make sure it’s on the radar for a New Year action. Key dates to note-

For Small Producers

By 1^st April 2026 (annually) register with the environmental regulator as a Small Producer. You can either register yourself on the report packaging data service or join a compliance scheme. NOTE – the vast majority of businesses with an obligation to join a compliance scheme to simplify the process. If you choose to join a compliance scheme this will bring forward deadlines so they’re able to check data prior to submitting it on your behalf.

By 1^st April 2026 – Submit your annual data (type and weight of packaging) for January – December 2025 to the regulator (Environment Agency, SEPA, NRW or NIEA) via the UK wide report packaging data service, managed by PackUK.

For Large Producers

By 1^st October 2026 (annually) – register with the environmental regulator as a Large Producer. You can either register yourself on the report packaging data service or join a compliance scheme. NOTE – If you join a compliance scheme, they will bring forward deadlines so they’re able to check data prior to submitting it on your behalf.

By 1^st April 2026 – Submit your 6-month data for July – December 2025 to the regulator (Environment Agency, SEPA, NRW or NIEA) via the UK wide report packaging data service, managed by PackUK.

By 1^st April 2026 submit your annual nation data for January – December 2025.

Action Now

1^st April may be a fair way off BUT working this back to when ‘compliance schemes’ need the data the following dates generally apply: –

January – collation of data for internal company verification.
Mid-February – Uploading data to the compliance scheme.
End of February – compliance scheme deadline for submission of data to regulator.

If you think you may have obligations under any of the packaging regulations such as EPR, but need some help in confirming this. Or in working out the data to be collected, collated and submitted. Or indeed if you’ve been submitting your data for a number of years but are now confused by ‘nation data’ requirements etc.

Please do call or email our team on 01743 343403 or mandy@e4environment.co.uk .