Packaging EPR: what small producers have to report

Under UK packaging EPR, a small producer (turnover over £1 million and more than 25 tonnes of packaging a year, but not over both £2 million and 50 tonnes) must register and report the weight of its packaging by material once a year, by 1 April. Data for 2026 is due by 1 April 2027. The registration fee is £1,216, or £631 through a compliance scheme, and small producers pay no waste disposal fees.

Updated 19 October 2026 by the Carbon Recycling team. Figures use the official UK government conversion factors and are checked against the current gov.uk guidance.

Are you a small producer?

Packaging extended producer responsibility (EPR) moves the cost of dealing with household packaging waste from taxpayers to the businesses that put packaging on the UK market. You are a "producer" if you do any of these: supply filled packaging under your own brand, pack or fill goods, import goods in packaging, supply empty packaging you make or import, hire or lend reusable packaging, run an online marketplace, or sell filled packaging to the end user.

Whether you have obligations, and which, depends on last year's packaging weight and your turnover:

Packaging supplied or imported	Turnover £1m or less	£1m to £2m	Over £2m
Less than 25 tonnes	No obligation	No obligation	No obligation
25 to 50 tonnes	No obligation	Small producer	Small producer
More than 50 tonnes	No obligation	Small producer	Large producer

"Small" here has nothing to do with headcount. For 2026 data, the weight test uses packaging from 1 January to 31 December 2025, and turnover comes from the last accounts available before 7 April 2026. A holding company applies the test to the whole group, counting only the companies that handle packaging. Charities are exempt, though their trading subsidiaries are not.

What a small producer has to do

Create an account on the government's report packaging data service. Only a director, company secretary, partner or LLP member can set it up; they become the "approved person", legally responsible for the data being as accurate as reasonably possible.
Collect the data through the calendar year: your packaging activities, the class of packaging, the material, the weight of each material in kilograms, and plastic and paper bags supplied in England.
Register and report by 1 April each year. You upload your organisation details and packaging data as CSV files, pay the registration fee (£1,216, or £631 through a compliance scheme), and the regulator considers your registration once the data is in.

Small producers report plastic as a single material, record all drinks containers as household drinks containers, and use only the codes SP and HDC. If you correct data after submitting, a resubmission fee may apply: £807 direct or £512 through a scheme. Large producers report every six months, pay waste disposal fees and buy recycling notes; small producers do neither.

You report to the regulator for your nation: the Environment Agency, Natural Resources Wales, SEPA or the Northern Ireland Environment Agency.

The carbon link

EPR is reported in kilograms, not CO2e. But once you are tracking packaging by material and weight, you have most of what you need to put packaging into your carbon footprint:

Packaging you buy is Scope 3 category 1, purchased goods and services. Without supplier figures, the spend-based method gives a first estimate. With Defra's 2023 multipliers, £45,000 of boxes (paper and stationery) is about 30.11 tonnes CO2e and £15,000 of film and trays (rubber and plastic products) about 9.66 tonnes.
What happens to it after your customers unpack it is Scope 3 category 12, end-of-life treatment of sold products. In the accounts the route makes a big difference: with the 2026 government factors a tonne of mixed paper and card sent to landfill counts as 1,165 kg CO2e, but recycled it counts as 5 kg. That's because landfill emissions stay with you, while the recycling factor only covers collection and delivery to the first processor; the rest is reported by whoever uses the recycled material.

The government's methodology warns that these waste factors are for Scope 3 reporting and can't be used to compare the full impact of different waste routes. The direction is still clear: less packaging, and packaging that is easy to recycle, which is what EPR is designed to encourage. For the tax on plastic packaging, see our post on Plastic Packaging Tax and carbon. Our post on what recycling saves compared with landfill goes further into disposal routes.

How Carbon Recycling helps

Carbon Recycling doesn't file EPR data: that goes through the government's report packaging data service. It does handle the carbon side. Import your purchase ledger and it suggests a Defra multiplier for each account, asking you to choose the closest match for packaging and materials, so your packaging purchases land in Scope 3 category 1 alongside everything else. Waste from your own sites goes in by material and treatment route in category 5. See our post on spend-based Scope 3 for the method.

Frequently asked questions

Am I a small producer under packaging EPR?

You are a small producer if your annual turnover is over £1 million and you supplied or imported more than 25 tonnes of packaging in the UK in the previous calendar year, unless you are over both £2 million and 50 tonnes, which makes you a large producer. Below £1 million or 25 tonnes you have no EPR obligation. For groups, the test uses the whole group's packaging and turnover.

When do small producers report packaging data?

Once a year, by 1 April, for the previous calendar year. Data for January to December 2026 is due by 1 April 2027, along with the year's registration and fee.

What does packaging EPR cost a small producer?

A registration fee each year: £1,216 if you register directly, or £631 if a compliance scheme registers you (the scheme charges for its services as well). Small producers don't pay waste disposal fees or buy packaging recycling notes (PRNs).

What packaging data do small producers collect?

Your packaging activity (such as selling, packing or importing), the packaging class, the material, the weight of each material in kilograms, and plastic and paper bags supplied in England. Small producers report plastic as one material and use the codes SP and HDC.

Is packaging EPR the same as Plastic Packaging Tax?

No. EPR covers all packaging materials and is run by the environmental regulators. Plastic Packaging Tax is an HMRC tax on plastic packaging made or imported with less than 30% recycled plastic, with a 10 tonne threshold. A business can be caught by both.

Does packaging EPR data count as carbon reporting?

No, it's reported in weight, not emissions. But the weights by material are exactly what you need to estimate the emissions from the packaging you buy and from its disposal by your customers, which sit in your Scope 3.

Plastic Packaging Tax: what it is and how it links to carbon
The 2026 rate, who registers, the April 2027 changes and where plastic packaging sits in your Scope 3 footprint.
ISO 14064-1 explained: do you need it?
The ISO greenhouse gas inventory standard in plain English: its six categories, how it compares with the GHG Protocol, and when you need it.
ISO 14001 and your carbon footprint
What ISO 14001:2026 and the climate amendment mean for carbon, and how a footprint gives your management system numbers to manage.

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