Extended Producer Responsibility (EPR) - McGrady Clarke
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Extended Producer Responsibility (EPR)

Supporting your organisation in meeting UK EPR obligations, managing data reporting, regulatory requirements and sustainability goals. We also help navigate EU PPWR for UK businesses placing packaged goods on the EU market.

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What is Extended Producer Responsibility (EPR)


EPR is environmental legislation requiring businesses or organisations to be responsible for the impact and future recycling of their product and/or associated packaging. Holding businesses accountable for the full cost of managing packaging when it is removed/discarded; product reaching end-of-life.

EPR requires businesses to pay now for the future recycling burden products or packaging create.

The UK has three types of EPR:

  • Packaging EPR
  • Waste* Electrical and Electronic Equipment (WEEE EPR)
  • Waste* Batteries & Accumulators (Batteries EPR)

*Don’t let the term “waste” mislead you.  EPR legislation applies to new-to-market products or packaging.

EPR incentivises Producers to create more recyclable and sustainable products and packaging. Moving the UK towards a more circular economy and playing an important part in contributing towards Net Zero.

Our experts have efficiently guided some of the UK’s largest producers through compliance and ongoing reporting, and are here to guide your business every step of the way. We will advise you on your obligations and requirements so your business can make an informed choice on how it achieves compliance.

Who must comply with EPR?

Businesses in the UK are obligated to collect and report packaging data under EPR if they meet all of the following criteria:

  1. An individual business, subsidiary or group (but not a charity).
  2. Annual turnover of £1 million or more (based on your most recent annual accounts up to 7th April).
  3. Responsible for more than 25 tonnes of packaging (previous calendar year).
  4. Carry out any of the following packaging activities:
      • Supply packaged goods to the UK market under its own brand.
      • Place goods into packaging that’s unbranded when it’s supplied.
      • Imports products in packaging.
      • Online Market Place: own an online marketplace.
      • Hire or loan out reusable packaging.
      • Supply empty packaging.

The key obligations of Packaging EPR include the possibility of multiple reporting requirements, to register through the government RPD portal or a Producer Compliance Scheme, and ensuring all obligated packaging is liable for PRN fees (tonnage fees). Additionally, household (HH) packaging will be subject to government fees (further tonnage fees).

You are considered a Producer and therefore obligated to collect and report data under WEEE if it meets at least one of the following criteria:

  • Manufacture and sell EEE under their own brand in the UK.
  • Buy EEE and then make changes to rebrand the product and resell it to the UK.
  • Import EEE on a commercial basis into the UK.
  • Are established outside of the UK and supply EEE directly to the UK market by distance selling e.g. online, mail order, or by phone.

Those acting as distributors may be obligated as a Producer. Producers can also be distributors and have additional take-back obligations.

Key obligations include joining a Producer Compliance Scheme (PCS), reporting the amount of EEE you place onto the market, financing the collection, treatment, and recycling of WEEE (tonnage fees), marking EEE devices with the appropriate symbols, and providing information to end users on how to recycle their WEEE.

You are considered a Producer and therefore obligated to collect and report data under Battery EPR if they meet all of the following criteria:

  • Any person who professionally, irrespective of the method used, places batteries, including those already in appliances or vehicles, on the UK market for the first time.

Those businesses distributing batteries directly to end users will also have distributor obligations. Businesses can be both a Producer and/or a distributor. Requirements will depend on the type of batteries you place on the UK market.

Key obligations include registering with the appropriate environmental regulator, reporting the amount of batteries you have placed on the UK market, and financing the collection, treatment, and recycling of waste batteries (tonnage fees) for larger producers. Larger producers must also register with a Producer Compliance Scheme, while small producers can register directly with the government. Additionally, businesses must provide information to end users on how to recycle batteries and report the amount of certain types of batteries taken back.

EU Packaging and Packaging Waste Regulation (PPWR)

If you are a UK business placing packaged goods on the EU market, then it is important to understand the distinction between UK EPR and the EU’s Packaging and Packaging Waste Regulation (PPWR). EU PPWR entered into force on 11th February 2025, with core requirements applying from 12th August 2026, affecting all 27 EU Member States.

EPR and PPWR share a common goal: making businesses accountable for the environmental impact of the packaging they place on the market. Both frameworks aim to improve recyclability, reduce waste, and shift the cost of waste management from governments to producers. However, EU PPWR is a comprehensive regulatory framework covering the full lifecycle of packaging, including design, materials, labelling, reuse, and recyclability. It also incorporates EPR as part of a wider system governing what packaging can be placed on the EU market.

Compliance with UK EPR does not ensure compliance with EU PPWR. Businesses operating across both markets must meet each set of requirements separately. Our team can support your business with navigating EU PPWR regulations as well as compliance with UK packaging EPR.

EPR
compliance process

Compliance assessment

A thorough review of the operational activities, establishing where your business has exposure under EPR. 

Data guidance & support

Review the available information within your organisation, determine your ability to meet the EPR requirements, co-develop an action plan and establish robust data collection systems.

Obligation calculation & report production

Using supplier data or in-house data to determine your obligations and produce the required data submissions to achieve compliance.

Registration & reporting

Whether registering directly with the government or through a Producer Compliance Scheme, we will complete the necessary actions, prepare and submit timely EPR reports and explain the financial obligations that your company has.

On-going support

Our service can be provided on an ad hoc project basis or as an ongoing business support partnership, with regular review meetings and reporting. Our team works closely with you to develop industry best practices, horizon scan for updates and manage regulator or compliance scheme audits.

We also support the procurement of Packaging Recovery Notes (PRNs), conduct compliance scheme reviews, and ensure you receive the best value.

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Packaging Recovery Notes (PRNs) are a key component of EPR compliance

A PRN is a piece of certified evidence that proves a tonne of packaging waste has been recovered and reprocessed or exported for reprocessing. When materials are exported for reprocessing, this is referred to as a Packaging Export Recovery Note (PERN). PRNs and PERNs can only be issued by accredited reprocessors or exporters.

Who needs PRNs?

Large Producers (over 50 tonnes of waste and £2 million in turnover) under Packaging EPR must purchase the equivalent number of PRNs to the amount of packaging they have placed onto UK markets.

You need one PRN for every tonne of household AND non-household packaging you are obligated to. Obligations & PRNs are assigned to specific materials. Your needs must match the material obligation you’ve incurred.

How PRNs work

PRNs confirm that a specific amount of packaging waste has been recycled or recovered.

Large Producers must obtain PRNs to demonstrate their contribution to the recycling system.

PRNs are assigned to specific materials. Your needs must match the material obligation you’ve incurred.

The cost of PRNs is determined by market supply and demand.

Ensuring efficient PRN procurement

PRNs are a commodity and the market can be volatile, businesses must adopt a strategic approach to PRN acquisition. Our consultancy service simplifies this process, ensuring seamless compliance while minimising costs and administrative burden.

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