Required actions for large organisations under packaging EPR

Introduction

This article explains the required actions for organisations classed as large under the Extended Producer Responsibility (EPR) for packaging regulations.

If you haven’t already done so, Identify if your organisation is impacted by packaging EPR and Identify if your organisation is classed as small or large.

Collecting data

As a large organisation, you should record data ready for reporting about the empty packaging and packaged goods you handle and supply in the UK from 1 January 2023.

This data must include:

• The packaging activity – how you put the packaging on the market

• The individual packaging materials and weights

• The packaging class – for example, primary, secondary, shipment or transit

• The packaging type – for example, household, non-household, street bin, drinks container, reusable or self-managed waste

This data requirement, including the material categories, is more complex than the old producer responsibility requirements that EPR replaces. We have an article covering this data task in more detail for you, Understand your packaging EPR data requirements.

Registering your organisation

As a large organisation you must create an account on a new government website and enrol your organisation from 16 August 2023. You must also pay an annual fee to the environmental regulator. Once you have enrolled you can specify a compliance scheme, such as Ecosurety, to submit data on your behalf.

Submitting your data

Under the EPR measures, your collected data must be submitted online every six months, within a three-month reporting window after the first and second half of the year.

The first six months of data from January to June must be submitted between 1 July and 1 October that year. The second six months of data from July to December must be submitted between 1 January and 1 April the following year.

The table below outlines the data collection and reporting requirements for large organisations:

Important data reporting update

The Environment Agency (EA) issued a Regulatory Position Statement (RPS) on 11 February 2025 outlining that producers who do not submit their 2024 or 2025 nation of sale data, or their self-managed organisation waste figures relating to the same period, will not normally be penalised by the environment agencies.

To be clear, it is still a regulatory obligation under the EPR legislation to collect and report this data, but if producers do not do so it is unlikely any enforcement action will be taken. The RPS will be revoked on 31 December 2026, meaning businesses will need to ensure they collect the relevant data from 1 January 2026 and submit it according to the deadlines. Refer to 'Timelines for Packaging EPR Implementation' for an overview of reporting deadlines.

If a producer only has an obligation to report nation of sale data, they still need to register in accordance with the regulations. The RPS only relates to the reporting of nation of sale and self-managed organisational waste and does not apply to registration. Therefore, these producers will still need to pay a registration fee and indicate a nil data return to the environment agencies.

We encourage Ecosurety members who have self-managed organisation waste data and/or nation data ready in 2025 to submit it to us for reporting to government as normal. Obligated Ecosurety members who do not have this data ready in 2025, must ensure they are ready to report it from 2026 when the relaxation of the requirement ends.

Nation data reporting

There is an additional nation data reporting requirement which may apply to your organisation if your annual turnover is more than £1m and you handle or supply more than 25 tonnes of packaging in a calendar year. This requires you to identify which country in the UK your packaging has been sold, hired, loaned, gifted or discarded in.

You must submit nation data if you do any of the following:

• Supply filled or empty packaging directly to consumers in the UK, where they are the end user of the packaging

• Supply empty packaging to UK organisations that are not legally obligated under the packaging EPR regulations or are classed as a small organisation

• Hire or loan out reusable packaging

• Own an online marketplace where organisations based outside the UK sell their empty packaging and packaged goods to UK consumers

• Import packaged goods into the UK and you discard the packaging

This data is reported separately and to a different deadline. The first data reporting deadline will be 1 December 2025 to report 2024 nation data, although you will be required to collect the data from 2023, even though the first reportable data relates to 2024 packaging. The deadline will then be in April every year after that.

Find out more in our article Understand the nation data requirement.

Plastic and paper bag reporting

Large and small producers who sell or supply plastic and paper bags in England must report the number of bags they have supplied by 1 April to the Environment Agency, for the previous calendar year. The first reporting deadline will be 1 April 2026, for bags supplied between 1 January and 31 December 2025.

Bags that need to be reporting are single-use carrier bags as defined under the Single Use Carrier Bags Charges (England) order 2015, bags made wholly or partly from plastic which are supplied to package food items such a bread or fruit, and unsealed paper bags that have handles.

Financial obligations

Large organisations will need to pay a fixed annual fee when registering. Most large organisations will also have significant financial obligations under the EPR regulations, based on their packaging obligation.

From 2024 you must buy evidence of recycling via Packaging waste Recycling Notes (PRNs) or Packaging waste Export Recycling Notes (PERNs), in accordance with the quantity and material types of all the packaging you have handled or supplied. This directly funds the recycling of packaging materials and enables you to work towards meeting your recycling target. A compliance scheme, such as Ecosurety, can purchase the required amount of PRNs for you.

For any packaging identified as likely to end up being collected by local authorities from households or public bins, from October 2025 you must also pay the scheme administrator, PackUK, a fee and a waste management fee, in addition to the PRN obligation. Funds collected via the waste management fee are distributed to local authorities, to cover the cost of collecting and sorting packaging waste from households and street bins.

The scheme administrator will treat all primary and shipment packaging as household waste, unless you can clearly evidence that the packaging is supplied directly to a business end-user.

The fee level per material is under consultation and government have given an indication of the base fees, outlined in the article linked to below. From 2026 the waste management fee will be modulated depending on how easily the packaging can be recycled. The fee will be lower for packaging that is easier to recycle.

Find out more details about this in the article Understand your packaging EPR costs.

Mandatory labelling

Defra removed text around labelling provisions from the EPR statutory instrument (SI) that were passed in December 2025.

This was because if the labelling provisions remained in the legislation, it was thought that there would be difficulties in passing the EPR regulations as a whole due to complexities surrounding the Windsor Agreement and maintaining a soft border between Northern Ireland and the Republic.

Defra stated that they are still committed to introducing a form of mandatory labelling to the EPR system, and that this is a “temporary position…and [that their] approach is likely to be consistent across all nations of the UK. In preparing these provisions, we will review the forthcoming EU packaging legislation and explore the potential for consistency across our approaches”.

It is therefore unclear at present what mandatory labelling provision will be in the place, and when producers will have to start complying with it. We recommend packaging producers continue to use the OPRL scheme to ensure their consumers clearly understand how they should correctly dispose of their waste.

Previously, it was understood that all primary and shipment packaging, including films and flexibles, should bear the OPRL 'Recycle Now' mark by April 2027 as described below, but it remains to be seen whether this will still be the case and when this obligation will apply. Find out more in our article Understand mandatory packaging labelling.

gov.uk EPR obligation checker

Government have provided an online tool to check if you have any packaging EPR data obligations. This can help you determine what required actions your organisation may have. To visit the gov.uk checker please click here.

Next steps

We recommend that you start getting to grips with your packaging data as soon as possible. Our next article walks you through exactly what you need to capture and when - Understand your packaging EPR data requirements.

External references

gov.uk EPR obligation checker tool

Read the official packaging EPR guidance on gov.uk

Read more about the illustrative base fees on gov.uk

Page updates

5 March 2025 - We corrected the annual nation data reporting deadlines from 2026 to 1 April.

25 February 2025 - We updated the data reporting timeline to include plastic and paper bag reporting, the 'Submitting your data' section to add an update from government and we added a new 'Plastic and paper bag reporting' section.

23 January 2025 - We updated details on the nation data requirement, mandatory labelling and add a link to PackUK, the new scheme administrator.

8 January 2025 - We removed details that are no longer required relating to the spearate PRN data submission.

11 October 2024 - We updated the first nation data reporting deadline to 1 December 2025.

3 October 2024 - We updated the 'Mandatory labelling' section due to this requirement being delayed by government.

21 August 2024 - We added information about the illustrative base fees released by government.

25 April 2024 - We updated the timeline and 'Mandatory labelling' section to update the start date of all mandatory labelling to 1 April 2027.