UK EPR for packaging: what overseas sellers and marketplaces owe (pEPR)

UK packaging EPR (pEPR) binds only a business that is established in the UK. A seller with no UK presence that ships to UK buyers is not a producer under it, and the regulations name no representative to appoint (SI 2024/1332 reg. 15). A UK branch, warehouse, PO box or any address where you receive post or returns makes you established. You are then obligated once you supply more than 25 tonnes of packaging a year and your worldwide turnover is above £1 million (reg. 24).

The EU rule, and who counts as a producer there, is in packaging EPR in the EU. In the EU a seller outside the EU that ships straight to the buyer is the producer. The UK works the other way round. This page is only what the UK adds. The other UK rules are on the United Kingdom page.

The law is SI 2024/1332, made on 11 December 2024 and in force from 1 January 2025, amended from 1 January 2026 by SI 2025/1369. It replaced the Packaging Waste (Data Reporting) (England) Regulations 2023, which were revoked on 1 January 2025. It applies in England, Scotland, Wales and Northern Ireland alike (reg. 1(4)).

The UK rule reaches only businesses established in the UK

A person is a producer only if it is established in the UK and performs a producer function in the UK, in the course of business (reg. 15(1)). A person is established in the UK in any of three cases (reg. 4):

• it is habitually resident there;
• its registered office, or without one its head office or principal place of business, is there;
• it has a branch or postal address there.

The four regulators say what a postal address is. For a business based abroad it can be a PO box, an office, a warehouse or domestic premises used for the business. It does not have to be premises you own. An address where you can receive post or returned items is enough to be a UK presence. A UK subsidiary does not make its foreign parent established, because the subsidiary is a separate legal entity (agreed positions, version 8, section 17). An address in the EU or anywhere else outside the UK does not count.

What a seller outside the UK does

Defra’s guidance lists selling filled packaging to an end user as a packaging activity. It counts only for a business that is already established in the UK.

If you also ship from the UK to buyers in EU countries, the EU rule applies to those sales. That is in packaging EPR in the EU.

You are obligated above 25 tonnes and £1 million

The table follows reg. 24 and Defra’s table. Three points decide the result:

• Turnover is the whole business, worldwide. The regulators count both UK and overseas turnover (agreed positions, section 9).
• The years are fixed. Tonnage is the packaging you supplied two calendar years before the year you register for; turnover comes from the last accounts available before 7 April of the year before that year. To register for 2027 you count packaging supplied from 1 January to 31 December 2025, and the accounts available before 7 April 2026.
• A group is tested together. You add up every group company established in the UK that supplies packaging. If the total is large, each member is large (Defra).

Charities are excluded from the producer obligations (reg. 12). Packaging that is a deposit item under a deposit scheme for drinks containers is exempt (reg. 11(1)(c)).

If you are obligated, do this in this order

1. Decide large or small with the table above.
2. Choose how to register. You register directly with your regulator, or through a compliance scheme. A scheme can register you, pay your registration fee, report your data and, for a large producer, buy packaging waste recycling notes (PRNs) and export recycling notes (PERNs). It cannot pay your disposal fee. The register of compliance schemes lists the approved ones. A compliance consultant does not take over your legal responsibility (Defra).
3. Create an account on the Report packaging data service. The account holder is a director or company secretary, a partner, a member of an LLP or a sole trader. The regulator checks the person, which can take up to 28 days. Until then you cannot register or report.
4. Know your regulator. It follows your registered office, head office or principal place of business in the UK. With none, you have the agency for the nation you named in a notice under regulation 3(3) of the 2023 Data Regulations, if you gave one. Otherwise you choose the Environment Agency, SEPA, Natural Resources Wales or DAERA once, by written notice, and cannot change it (reg. 5(2)).
5. Upload your registration file, pay the fee and submit. The regulator decides after it has your registration details, your packaging data and the fee. A small producer’s application is not considered until the packaging data is in (Defra).
6. Report your packaging data on the dates below and keep the data for 7 years.
7. Large producers only: meet the recycling obligation and pay the disposal fee. You buy PRNs and PERNs for each material. For 2026 the deadline is 31 January 2027. PackUK sends a notice of liability for the disposal fee. You must also assess the recyclability of the household packaging you supply, keep records of the assessments and report them to your regulator (reg. 25(3), reg. 26).
8. Tell the regulator of any change within 28 days. This includes stopping being a producer (reg. 31).

A large producer whose only class is seller does steps 1 to 6 and 8 only. It has no recycling obligation (reg. 25(2)) and pays no disposal fee, because reg. 60(1) leaves the seller class out of the producers who pay. This fits only a business that buys goods already in the UK and resells them. If you import them or they carry your brand, you are an importer or brand owner (reg. 18, reg. 16), not seller only, and all eight steps apply.

Deadlines

Sources: reg. 28, reg. 35, Defra’s deadlines page, recycling obligations, PackUK notice. An online marketplace also files a methodology on how it collected its data, by 1 April each year for the previous calendar year (Defra). The cut-off to resubmit 2025 data and still change the 2026 to 2027 fees was 1 September 2026.

What it costs

The registration charge is set in Schedule 1 and has applied since 1 January 2026:

You pay the registration charge each year. A compliance scheme also charges its own fee, and no official figure exists. Defra’s small producer page still shows the earlier £1,216 and £631; the Schedule in force says £1,303 and £696.

A large producer also pays a disposal fee to PackUK for household packaging, by weight and material. The base fees for the first year, 2025 to 2026:

Source: PackUK, 2025 base fees. From 2026 to 2027 the fee changes with how recyclable the packaging is. Modulation applies to the household packaging waste disposal part of the fee, which is a significant component of the base fee. For packaging rated red under the recyclability assessment, that part is multiplied by 1.2 in 2026 to 2027, 1.6 in 2027 to 2028 and 2.0 in 2028 to 2029. Amber pays the base fee. Green pays less, because the extra money from red funds an equal percentage discount on green (PackUK modulation statement). PackUK published illustrative fees for Year 2, 2026 to 2027, in December 2025. On 6 July 2026 it said it does not intend to publish further illustrative fees and that the confirmed figures would follow later in 2026 (PackUK, 6 July 2026). PackUK has not published the confirmed fees yet.

The recycling obligation is a share of the weight you reported, bought as PRNs and PERNs for each material. The business targets are:

Source: Defra, recycling obligations and waste disposal fees.

An online marketplace is the producer for sellers outside the UK

A person is an online marketplace operator if it controls access to and the content of the marketplace and is involved in the terms of sale, in the payment, and in the ordering or delivery (reg. 20(1)). Such an operator is a producer for:

• packaging on items that a non-UK supplier supplies on the marketplace and that are received in the UK;
• unfilled packaging that a non-UK supplier supplies there to a business that is not a large brand owner, packer/filler or first UK owner.

The operator must itself be established in the UK to be a producer (reg. 15(1)(a)). Its registration costs £2,885 more than another producer’s, and it pays the disposal fee as a large producer if it is one (reg. 60). A non-UK seller on the marketplace is not a producer for that packaging, so there is no producer registration of its own to make.

The regulators and PackUK check the register

The register of producers is public and updated daily. The Environment Agency says it monitors to find unregistered producers that are obligated and bring them into compliance, and that its monitoring covers online marketplaces (monitoring plan 2026). Anyone can report a business that should be on the register to its regulator (Defra). PackUK is the scheme administrator: it sets the disposal fees and collects them.

If you do nothing

For a business with no UK presence, pEPR sets no penalty, because it sets no duty. For a producer established in the UK that does not register or report, the appropriate agency has these sanctions (Schedule 13, reg. 115):

An offence is punishable by a fine on conviction. In England and Wales the fine is unlimited: reg. 119 sets no cap, and section 85 of the Legal Aid, Sentencing and Punishment of Offenders Act 2012 removed the limit on magistrates’ court fines. In Scotland and Northern Ireland a summary fine cannot exceed the statutory maximum. A director or other officer is also guilty where the offence happened with their consent or connivance or through their neglect (reg. 120). An unpaid fixed penalty rises by 50% after 56 days. The regulator can cancel a registration for false information (reg. 32).

What does not apply

• A packaging representative. The regulations name none for a producer. The word appears only for the person who receives a PRN or PERN.
• A mandatory recycling mark or other labelling duty. SI 2024/1332 sets no labelling duty. The Deposit Return Scheme is separate: from 1 October 2027 in England and Northern Ireland, drinks containers in the scheme carry scheme labelling, and the producer must be registered with the deposit management organisation (SI 2025/67 reg. 1, Defra). Scotland legislates for its scheme separately.
• A producer registration number for a seller with no UK presence. Such a seller is not a producer, so the marketplace is the one that registers.
• The EU registers and the EU producer rule. pEPR is a separate UK system. What applies to sales into EU countries is in packaging EPR in the EU.