What Is pEPR?
Extended Producer Responsibility (EPR) is a new UK government scheme that changes who pays for the disposal of packaging waste. If your business uses cardboard packaging to sell, import, or ship products in the UK, this scheme will affect you directly.
According to the UK Government's official guidance (available at gov.uk/pEPR), the new rules will:
- Shift the cost of managing household packaging waste from local authorities (and by extension, taxpayers) to the producers of that packaging.
- Apply to any business placing packaging on the UK market, particularly larger businesses with a turnover over £2 million or that handle more than 50 tonnes of packaging a year.
- Introduce fees based on material type and recyclability, which includes cardboard.
What This Means for Your Business
If your business ships products in cardboard boxes, you will be required to pay fees under this scheme, even though cardboard is widely recyclable.
In December 2024, DEFRA published its illustrative base fees (see the gov.uk December update): (gov.uk – December Update):
| Material | Rate (£ per tonne) |
|---|---|
| Paper/Board | £215 |
For example, using 10 tonnes of cardboard in a year would result in fees of £2,150. This is before modulated fees are introduced in 2026, which are expected to increase costs for packaging that is harder to recycle, such as material with plastic coatings or tape.
How to Minimise the Impact
Audit your packaging use. Establish exactly how much packaging you use. This data will also be required for the mandatory reports you'll need to submit to the Environment Agency.
Reduce packaging volume. Using fewer or smaller boxes reduces your overall fees. Simpler packaging designs also tend to be cheaper to recycle, which may help reduce costs once modulated fees are introduced.
Choose recyclable, uncoated materials. DEFRA has indicated that more sustainable packaging will be treated more favourably under the fee structure. Packaging that is recyclable and free of plastic laminates or metallic finishes is likely to attract lower costs once modulated fees begin.
Work with suppliers who understand the requirements. Some packaging suppliers already offer EPR-compliant solutions. Ask whether their products meet UK recyclability standards, and consider alternative suppliers if they cannot confirm this.
Prepare for reporting obligations. Businesses classed as "large organisations" must submit packaging data twice a year. Missing a deadline can result in a fine. Further details are available in the EPR Reporting Guidance.
Understanding Your Producer Category
Under pEPR, obligations vary depending on your business's size, role, and packaging activities. Below is a breakdown of the main categories.
Small Producers
- Criteria: Turnover between £1 million and £2 million, and handling 25 to 50 tonnes of packaging per year.
- Obligations: Reporting packaging data only. Disposal fees will typically be included in your packaging supplier's pricing, or added as a separate line on your invoice.
Large Producers
- Criteria: Turnover over £2 million, and handling more than 50 tonnes of packaging per year.
- Obligations: Submission of packaging data and payment of full disposal fees based on material type and quantity.
Brand Owners
- If you manufacture goods and apply your own brand to them (or authorise someone else to do so), you are classed as the brand owner and are responsible for the packaging used on those products, regardless of who ultimately sells them.
Importers
- Businesses that bring packaged goods into the UK take on responsibility for that packaging's waste management, even if they were not the ones who originally packaged it.
Distributors / Business-to-Business Sellers
- Businesses that supply unbranded packaging to other businesses still have reporting obligations under the scheme. For example, a business selling plain cardboard boxes to other retailers is classed as a B2B distributor and must share in the reporting requirements.
Summary
pEPR will increase costs and add administrative requirements for businesses using packaging in the UK. However, it also presents an opportunity to review and improve packaging practices, which can appeal to increasingly eco-conscious customers.
In short: if your business uses cardboard packaging in the UK, pEPR means new costs are coming. Audit your packaging usage, look for ways to reduce and simplify it, and stay on top of your reporting obligations to avoid penalties.
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