The UK’s packaging Extended Producer Responsibility (pEPR) scheme makes businesses that put packaging on the UK market pay for its collection, recycling and disposal. For US brands shipping to the UK, the hard part is working out whether the rules land on you, on your UK importer, or on the marketplace you sell through.
This guide covers who counts as an obligated producer, how to size yourself as a small or large producer, the registration steps on the government’s Report Packaging Data service, and the mistakes that trip up overseas brands. Rules and deadlines change, so confirm details on GOV.UK before you file.
Quick Answer
UK packaging EPR applies to a business that is established in the UK, has annual worldwide turnover of £1 million or more, and supplied or imported more than 25 tonnes of packaging in the previous year. A US brand is usually caught in one of two ways: it has a UK presence (a branch, warehouse or UK postal address), or it sells through a UK importer or marketplace that takes on the obligation. If you are caught, you register on the Report Packaging Data (RPD) service.
Step 1: Work Out Whether You Are an Obligated Producer
GOV.UK lists the activities that make you a packaging producer. They include supplying filled packaging under your own brand, packing goods or filling packaging, importing goods in packaging, supplying unfilled packaging you make or import, hiring or loaning out reusable packaging, selling filled packaging to an end user, and operating an online marketplace through which packaging is supplied in the UK.
To be an obligated producer you must meet all three tests: you are established in the UK, you supplied or imported more than 25 tonnes of packaging in the previous year, and your annual worldwide turnover is £1 million or more. Turnover is counted worldwide, so US revenue counts toward the £1 million.
‘Established in the UK’ is broader than it sounds. It covers a registered office, head office or principal place of business in the UK. It also covers a UK branch, a UK warehouse, or a UK postal address. A US brand with a UK returns address or a UK 3PL warehouse should not assume it sits outside the rules.
Who is the producer also depends on who does the importing and packing. If another organisation imports or packs your goods under your brand, the brand owner can still carry obligations. Ask your UK distributor or importer in writing who is treating themselves as the producer for each packaging item, so that packaging is neither missed nor reported twice.
Step 2: Determine Small or Large Producer Status
Below 25 tonnes of packaging, or £1 million turnover or less, you have no obligation. With 25 to 50 tonnes and turnover over £1 million, you are a small producer. With more than 50 tonnes and turnover between £1 million and £2 million, you are also a small producer. With more than 50 tonnes and turnover over £2 million, you are a large producer.
Large producers register every year, report packaging data every six months, and purchase recycling notes (PRNs/PERNs). Small producers register and report once a year and have fewer obligations. Both must keep records for seven years.
Estimate your tonnage by weighing every packaging component you supply in the UK: primary packaging, shipping boxes, void fill, tape and labels, split by material such as plastic, paper and card, glass, metal and wood. Your packaging supplier’s specifications and your 3PL’s shipment records are the fastest sources.
Step 3: Register on the Report Packaging Data Service
Registration is done online in five steps. Create an account on the RPD service, check which registration details your organisation type needs, upload your registration details file, submit the uploaded details (a separate action from uploading), then review the fees, pay and submit the application.
The account creator must be a director, company secretary, partner, sole trader, or a member of a limited liability partnership (LLP). The environmental regulator has to verify that person as an approved person, which can take up to 28 days, and you cannot submit your application until that is done. Start early.
Large producers had to register for 2027 by 1 October 2026. There is a later deadline of 1 April 2027 if your only packaging activity is selling filled packaging directly to an end user. Missing the deadline can bring a late fee and enforcement action. Registration fees apply, so check the current fee table on GOV.UK rather than relying on a figure quoted in an old article.
Tips and Common Mistakes
Do not assume selling only to consumers from a US website takes you out of scope. Selling filled packaging to an end user is a listed producer activity, and the rules on being established in the UK turn on details like a warehouse or returns address. If your position is unclear, ask the regulator or a compliance adviser.
Do not rely on a marketplace to cover you by default. Operating an online marketplace is itself a listed producer activity, but confirm with each platform how it handles packaging for third-party sellers and whether it needs data from you.
Avoid double reporting. Agree with your UK importer, distributor or 3PL who reports which packaging. Keep weight records by material and packaging type, and store them for the required seven years.
Consider a compliance scheme. Registering through one is a different route from direct registration, and schemes typically help large producers with recycling-note purchasing and reporting. Compare what each includes before you sign.
Explore more: More packaging compliance guides.
UK packaging EPR for US brands FAQs
Does UK packaging EPR apply to US companies?
It can. The obligation depends on being established in the UK (which includes having a UK branch, warehouse or postal address), plus meeting the 25-tonne and £1 million thresholds. Many US brands are affected through their UK importer or UK fulfilment setup.
What is the difference between a small and large producer under UK EPR?
Small producers supply 25 to 50 tonnes at over £1 million turnover, or over 50 tonnes at £1 million to £2 million turnover. Large producers supply over 50 tonnes and have turnover above £2 million. Large producers report every six months and buy recycling notes; small producers report annually.
Where do I register for UK packaging EPR?
On the government’s Report Packaging Data (RPD) service, where you create an account, upload your registration details and pay the fee. The account creator must be verified by the environmental regulator as an approved person first.
Is there a later deadline for direct-to-consumer sellers?
Yes. If a large producer’s only packaging activity is selling filled packaging directly to an end user, GOV.UK allows registration for 2027 by 1 April 2027 instead of 1 October 2026.
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Photo: Meanwell Packaging / CC BY 2.0, via Wikimedia Commons.