EPR Guide - Flipbook - Page 10
Who Needs to Comply?
Affected Businesses, Thresholds & Roles
Nearly any UK company involved in packaging supply could be obligated under EPR, including many
manufacturers, importers, distributors, retailers, and even logistics 昀椀rms using packaging. However,
there are threshold criteria to determine if you count as a “producer” under EPR and what your exact
duties are.
Thresholds: Large vs Small Producers
Your business must comply with EPR for packaging if you meet both of these thresholds:
• Annual UK turnover of £1 million or more, and
• Over 25 tonnes of packaging handled (supplied or imported into the UK) in the previous calendar
year.
If you do not exceed both thresholds, you are currently not obligated under EPR. Charities are exempt
from fees (though if they perform packaging activities, they may still need to register in some cases).
Companies that qualify are further classed as “small” or “large” producers, which affects their reporting
and fees:
Small vs Large Producer Thresholds
Small Producer: Turnover £1m - £2m, and 25-50 tonnes of packaging per year (or
turnover > £1m and ≤ 50t).
Large Producer: Turnover above £2m and >50 tonnes of packaging per year. (In practice,
‘large’ means you exceed both £2m and 50t thresholds.)
If your company is part of a group of companies, thresholds apply to the group as a whole via the parent
company. In other words, a corporate group must register and report as one entity (if collectively over the
limits, even if individual subsidiaries are below). Many large enterprises have registered at group level to
manage compliance centrally.
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