Packaging Extended Producer Responsibility (pEPR) Compliance Check

Why this matters

Since 2024, any UK business handling packaging with an annual turnover over £1 million and supplying or importing more than 25 tonnes of packaging must register under the Extended Producer Responsibility for Packaging (pEPR) scheme, reporting packaging data twice a year to PackUK by 1 April and 1 October. “Large producers” — turnover over £2 million and more than 50 tonnes of packaging — must go further and pay disposal fees covering the full cost of collecting, sorting, and recycling their packaging once it becomes household waste. PackUK issued the first Notices of Liability in October 2025, based on 2024 packaging data, with base fees around £423 per tonne for plastic and £192 per tonne for glass in the scheme’s first year. Many businesses that sell products in packaging — not just packaging manufacturers — are catching themselves out by assuming pEPR only applies to specialist packaging firms.

From the 2026 to 2027 fee year, flat base fees are being replaced by a recyclability-based modulation system: packaging rated red, amber, or green under PackUK’s Recyclability Assessment Methodology attracts an escalating fee multiplier (1.2x, rising to 1.6x and then 2.0x in later years), meaning poorly recyclable packaging becomes progressively more expensive to place on the market. The Environment Agency is now actively auditing packaging data submissions, and late or inaccurate reporting can trigger civil penalties of the greater of 20% of unpaid fees or a percentage of UK turnover, alongside possible criminal prosecution for serious non-compliance. Businesses that haven’t checked their obligated status, submitted data on time, or reviewed how their packaging will be rated under the new recyclability system risk fees and penalties that catch many by surprise in their first full year of enforcement.

What you'll need

• Your business's approximate annual UK turnover and whether it exceeds £1 million or £2 million
• The approximate tonnage of packaging your business supplies, imports, or places on the UK market each year
• Whether you have already registered with PackUK or the relevant environment agency
• Whether you have submitted packaging data for the required reporting periods (by 1 April and 1 October)
• Whether you have received a Notice of Liability or invoice for disposal fees

What you'll get

A personalised compliance report covering: a score out of 100, an executive summary, a list of findings ranked by severity, and a prioritised action plan with timeframes.