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OPINION: ‘EPR: Here’s what Small Producers need to do next’

John Redmayne, CEO of ERP UK, discusses the extended producer responsibility (EPR) threshold reduction and the next steps for small producers.


OPINION: If British businesses assumed packaging waste rules only applied to the big players, it’s time to think again.

John Redmayne, ERP UK

Quietly but decisively, the government has halved the thresholds under its Extended Producer Responsibility (EPR) scheme for packaging — and thousands of smaller UK businesses are now on the hook.

Previously, only firms turning over more than £2 million and handling over 50 tonnes of packaging a year needed to register. But under the updated rules, any business with a turnover of just £1 million and as little as 25 tonnes of packaging now falls under the spotlight.

A new category, defined as “Small Producers,” has been created by the legislation. While the reporting requirements for these businesses are lighter — and the immediate costs low — the risk of non-compliance is anything but. Miss the reporting deadlines or fail to register, and fines could follow.

For many smaller businesses, whether in floristry, pet food supplies or e-commerce fashion, this change could easily slip under the radar until it’s too late. Smaller businesses often don’t have the luxury of legal or compliance teams, so many aren’t even aware that they are now in scope.

Going unnoticed isn’t an option. The Environment Agency recently told trade magazine The Grocer that it took action against more than 1,000 companies in the five months to March 2025, to bring them in line with the EPR rules.

As readers of letsrecycle.com will be well aware, these rules aren’t just red tape – they’re part of the UK’s bigger environmental commitments so it’s important to take responsibility.

What’s the best way for Small Producers to proceed?

Get registered

Even though the 1 April 2025 deadline has come and gone, it’s not too late to take action. If you’re a Small Producer and want to future-proof your business for compliance, the sooner you get organised, the better. Firstly, check whether or not you are affected. The government has provided a handy online guide here.

If you meet the new thresholds, registering with your environment agency, and paying the right registration fee will be vital.

You’ve got two ways to handle your packaging obligations: you can either register directly with the Report Packaging Data service or sign up with an officially recognised compliance scheme.

If you go it alone, you’ll be responsible for the whole process — registering with the environmental regulator, reporting your packaging data, collecting the right evidence to prove your recycling targets are met, and submitting your certificate of compliance each year.

If you join a compliance scheme, they’ll handle all of that for you — from registration and reporting to making sure the right evidence is in place and submitting your annual certificate.

And just to be clear: if you’re using a compliance scheme, you don’t need to register separately with the regulator. The scheme will sort that out on your behalf.

To give an idea of cost, the annual registration fee when you register your company yourself is £1,216 for a small organisation, and £2,620 for a large organisation, with an additional “late fee” of £332 for those registering after the deadline. Fees via a compliance scheme are different.

It’s also important to build an understanding of exactly how much packaging your business handles. That means looking beyond what you send out to customers and considering the packaging you receive too. Start tracking what happens to your waste after it leaves your site — visibility here will help you make informed decisions about suppliers and recycling options.

Many businesses are finding it helpful to work with a compliance scheme that can handle the data side for them. These services can simplify compliance, reduce the risk of reporting errors and give you confidence that your business is meeting its obligations.

Others will feel confident to handle the paperwork and ongoing changes to the regulations themselves.

Smarter waste management

The new rules are part of a much bigger shift toward greener, more efficient waste management in the UK.

By casting the net wider, regulators hope to build a clearer picture of just how much packaging is flowing through the economy — a vital step in making sure more of it is recycled rather than sent to landfill. Even if your business isn’t quite over the threshold yet, now’s the time to take a closer look at your packaging use, and start planning ahead.

And while this isn’t technically a tax, from October the money raised will directly fund the collection and proper management of packaging waste — a move designed to create a cleaner, more circular system for everyone.

For smaller companies, it will help to view this as more than a box-ticking exercise; it’s a chance to stay ahead of the curve, avoid nasty surprises, and play an active role in driving a more sustainable future.

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