Helping your clients navigate EPR: Are they obligated packaging producers?

Under these rules, businesses that handle significant amounts of packaging may face strict obligations, and failing to comply can lead to financial penalties, reputational damage, and even criminal prosecution.

Understanding EPR is key for your clients’ risk management plans. Our specialist team have given us their top tips and guidance below, please feel free to pass this on to your clients.

What is EPR for packaging?

EPR shifts the responsibility for packaging waste management onto businesses that produce, handle, or supply packaging. If your client meets the criteria, they must register, report data, and pay fees to cover the cost of recycling and waste management.

Who is an obligated packaging producer under EPR?

A business is classed as an obligated producer if it meets both of these conditions:

• Handles 50 tonnes or more of packaging in a calendar year.
• Has an annual turnover of more than £2 million.

Group structures and thresholds

• If part of a group, combine packaging handled and turnover across all entities.
• Small organisations (turnover £1–2 million and handling 25–50 tonnes) have reduced obligations but must still report data.

What counts as handling packaging?

Handling means the business:

• Owns the packaging, and
• Performs (or commissions) at least one of the following activities:
• Manufacturing raw materials for packaging.
• Converting raw materials into packaging.
• Packing or filling goods.
• Selling packaged goods.
• Importing packaging or packaged goods.
• Providing packaging as a service (hire or loan).

Internal use of packaging does not count.

Key EPR deadlines

• Large organisations: Should have registered by 1 October 2025 for the 2026 compliance year.
• Small organisations: Should register by 1 April 2026.

Registration fees (current rates)

• Large organisation (direct registration): £2,620
• Small organisation (direct registration): £1,216
• Late registration fee: £332
• Compliance scheme fees:
• Large organisation: £1,685
• Small organisation: £631
• Group subsidiaries:
• First 20: £558 each
• 21–100: £140 each

(Fees will increase slightly from January 2026.)

Why this matters for brokers

Non-compliance can result in:

• Financial penalties and late fees.
• Criminal prosecution.
• Reputational harm.
• Loss of licenses or permits.

For brokers, this is a critical risk area. Advising clients on EPR obligations, and ensuring they have appropriate insurance, helps protect their business and strengthens your position as a trusted advisor.