Extended Producer Responsibility shifts the cost of managing packaging waste away from local authorities and onto the businesses that place packaging on the UK market.

If you are in scope, your legal duties may include:

• Registering with the regulator
• Collecting and submitting packaging data
• Paying EPR packaging fees from 2025 onwards

However, these obligations only apply if you meet the required thresholds.

The Two Key EPR Threshold Tests

To determine whether EPR applies to your business, you must assess both of the following:

1. Your annual UK turnover
2. The total amount of packaging you handle or supply in a year

If you do not meet the relevant thresholds, you may not need to register at all.

1. Businesses With Turnover Under £1 Million

If your organisation:

• Has an annual UK turnover below £1 million
• Handles or supplies any amount of packaging

You are not obligated under EPR and do not need to register or submit packaging data.

This exemption applies to a large number of SMEs who often assume EPR applies to them when it does not.

2. Small Organisations: Data Reporting Only

You are classed as a Small Organisation if:

• Your annual UK turnover is between £1 million and £2 million
• You handle or supply more than 25 tonnes of packaging per year

Your obligations are limited to:

• Registering with the regulator
• Submitting packaging data

You do not pay EPR packaging fees.

This is a common area of misunderstanding. Registration does not automatically mean future fees.

3. Large Organisations: Full EPR Obligations

You are classed as a Large Organisation if:

• Your annual UK turnover is £2 million or more
• You handle or supply more than 50 tonnes of packaging per year

Your obligations include:

• Registering under EPR
• Submitting detailed packaging data
• Paying EPR packaging fees
• Meeting recycling and reporting requirements

These businesses carry the full financial responsibility for packaging waste under EPR.

You may be obligated under EPR if you:

• Manufacture packaging
• Import packaged goods into the UK
• Sell packaged products to UK customers
• Supply empty packaging
• Operate an online or distance selling model

Packaging includes:

• Primary packaging (product packaging)
• Secondary packaging (grouping and transit packaging)
• Tertiary packaging (pallet wrap, shrink wrap, and similar materials)

We regularly see businesses caught out by:

• Registering unnecessarily when under the £1 million threshold
• Assuming all registered businesses must pay EPR fees
• Miscalculating packaging weights
• Missing deadlines due to uncertainty

These mistakes create avoidable admin, cost, and compliance risk.

Start with the basics:

1. Confirm your annual UK turnover
2. Estimate your yearly packaging tonnage
3. Apply the EPR threshold tests correctly

If you are unsure, seek guidance before registering.

At Flame UK, we help businesses get EPR right by:

• Assessing whether EPR applies to your organisation
• Accurately calculating packaging data
• Advising whether registration is required
• Building compliant, future-proof reporting processes

EPR does not have to be complicated. Getting clear answers early can save significant time, cost, and stress later.