Most small UK retailers do not have to register for packaging EPR. You only have obligations if your business is established in the UK, your worldwide annual turnover is £1 million or more, and you supplied or imported more than 25 tonnes of packaging in the UK last year. Miss either threshold and you have nothing to register, report or pay. Meet both and you become either a "small producer" or a "large producer", with very different workloads attached to each.
Extended producer responsibility sounds alarming until you check the numbers. Below is a plain-English walkthrough for retailers and e-commerce sellers who buy branded packaging, including where custom printed paper bags sit in the scheme and why your choice of material is starting to affect what producers pay.
What packaging EPR actually is
EPR shifts the cost of dealing with packaging waste away from councils and onto the businesses that put that packaging on the market. Rather than the taxpayer funding kerbside collection and sorting, obligated producers report what they supply and, above a certain size, pay disposal fees based on weight and recyclability.
The scheme is administered by PackUK on behalf of the four UK nations, with the Environment Agency, Natural Resources Wales, the Scottish Environment Protection Agency and the Northern Ireland Environment Agency acting as regulators depending on where your business sits.
Importantly, "packaging" is broader than most people assume. GOV.UK defines it as any material used to contain, protect, handle, deliver or present goods to an end user, which covers carrier bags, mailing bags, boxes, void fill, pallets, shrink wrap and display units.
Do you need to register? The two thresholds
You are an "obligated producer" only if all of the following apply, as set out in Defra's guidance on who must comply with EPR for packaging:
- your business, subsidiary or corporate group is established in the UK
- you supplied or imported more than 25 tonnes of packaging in the UK in the previous calendar year
- your worldwide annual turnover was £1 million or more
Both tests must be met. A £4 million business supplying 12 tonnes of packaging has no obligation, and nor does a £600,000 business shipping 80 tonnes. Charities are exempt altogether, although their profit-making trading subsidiaries are not.
Twenty-five tonnes is a genuinely large amount for a shop or online seller. As a rough illustration, if a medium paper carrier bag weighs around 35g, 25 tonnes is in the region of 700,000 bags. The threshold covers every scrap of packaging you handle though, not just your bags, so inbound cartons and despatch boxes count too.
Small producer or large producer?
If you do cross both thresholds, your classification depends on where you land:
- Small producer: turnover of more than £1 million and up to £2 million while supplying more than 25 tonnes, or turnover of more than £1 million while supplying between 25 and 50 tonnes.
- Large producer: turnover of more than £2 million while supplying more than 50 tonnes.
The label has nothing to do with headcount. A ten-person business with high turnover and heavy packaging volumes can be a large producer, while a fifty-person business under the tonnage line has no obligation at all.
What you have to do, and by when
Small producers get the lighter end of the deal. According to the GOV.UK guidance on what small producers must do, you register with your regulator, report packaging data once a year and keep the underlying records for seven years. You do not have to buy packaging waste recycling notes and you do not pay waste disposal fees.
The small producer registration fee is £1,216, dropping to £631 if a registered compliance scheme handles it on your behalf. Reporting runs on a calendar year: data for January to December is due by 1 April of the following year.
Large producers carry more. They register annually, report every six months, buy PRNs or PERNs to meet recycling obligations, submit a certificate of compliance, and pay PackUK a waste disposal fee for household packaging.
Why your choice of material is starting to matter
This is the part worth paying attention to even if you are nowhere near the thresholds today. Disposal fees are no longer a flat rate per tonne. Under the recyclability assessment methodology, household packaging is rated red, amber or green, and that rating modulates what a large producer pays.
Green means widely recyclable in current UK infrastructure. Amber means the packaging causes problems somewhere in collection, sorting or reprocessing. Red means it is difficult to recycle at scale and attracts the highest fees. Paper and board is one of the eight specified material categories assessed under the methodology.
Some things trigger an automatic red rating regardless of base material, including integrated electronics, certain substances of very high concern, and inks not manufactured in line with the EuPIA exclusion policy. That is a question worth putting to whoever prints your packaging.
The practical takeaway is that simple, single-material packaging tends to be easier to defend. A plain kraft or white paper bag printed with water-based inks is a less complicated proposition than a laminated, mixed-material equivalent. Our guide to recyclable, biodegradable and compostable packaging covers how those terms differ and why they are not interchangeable.
The England paper and plastic bag report
There is one wrinkle specific to bags. Small producers must collect data on plastic and paper bags supplied in England alongside the standard packaging categories, following a regulatory position statement issued by the Environment Agency. If you are obligated and you hand out carrier bags in England, keep those figures separate from the start.
EPR also sits alongside, not instead of, the single-use carrier bag charge, which we cover in our article on paper versus plastic carrier bags and the UK bag charge.
Three practical steps for retailers
- Weigh what you actually use. Ask suppliers for the unit weight of each item of packaging you buy, then multiply by annual volumes. Most retailers find they are comfortably under 25 tonnes and can stop there.
- Record as you go. If you are close to the line, build those weights into your purchasing records now rather than reconstructing them from a year of invoices.
- Ask what your packaging is made of. Material, coatings, inks and laminates all feed a recyclability assessment. If a supplier cannot tell you, that is informative in itself.
Frequently asked questions
Do I need to register for packaging EPR as a small business?
Only if you meet both thresholds. Your worldwide annual turnover must be £1 million or more and you must have supplied or imported more than 25 tonnes of packaging in the UK in the previous calendar year. If you fall below either figure, you have no registration, reporting or fee obligations under the scheme.
How much does it cost to register as a small producer?
The small producer registration fee is £1,216. If you use a registered compliance scheme to register on your behalf, the fee is £631, although the scheme will charge you separately for its services.
When is the EPR packaging data deadline?
Small producers report data for the previous calendar year by 1 April. For example, packaging supplied between January and December 2025 had to be reported by 1 April 2026. Large producers report every six months rather than annually.
Do printed paper bags count towards the 25 tonne threshold?
Yes. Carrier bags and mailing bags are packaging under the regulations, so their weight counts towards your total alongside cartons, boxes, void fill and anything else you supply or import. Only count each item once, even if you carry out more than one packaging activity on it.
Are paper bags cheaper under EPR than plastic ones?
Fees are set per material and modulated by recyclability, so the answer depends on the specific packaging and the rating it receives rather than the material alone. Paper and board is assessed as its own category, and packaging that is widely recyclable in current UK infrastructure attracts a green rating and lower modulated fees than red-rated packaging.
Who do I report to if I trade across the UK?
You report to the regulator for the nation your business sits in: the Environment Agency in England, Natural Resources Wales in Wales, the Scottish Environment Protection Agency in Scotland, or the Northern Ireland Environment Agency in Northern Ireland.
Simple packaging, printed properly
Whether or not EPR applies to you, straightforward paper packaging is an easy thing to stand behind. Fast Printed Bags prints supplied artwork onto stock kraft and white paper bags using full-colour water-based inkjet, across twist handle and tape handle carriers, paper mailing bags, wine bottle bags, stand-up pouches and general use bags. Printing covers defined front and back panel areas rather than the whole bag, which keeps the product simple and the material single-stream.
To see and weigh the stock before committing, order a sample pack or read our artwork and personalisation guidance.
This article is general information, not legal or compliance advice. Always check current GOV.UK guidance for your circumstances.