Packaging EPR for Small Producers: 2026 Reporting Obligations

Packaging EPR for small producers in 2026 introduces new registration, reporting and data collection requirements that many UK businesses may not realise apply to them. If your turnover exceeds £1 million and you place more than 25 tonnes of packaging onto the UK market, understanding your packaging EPR obligations is essential to remain compliant and avoid penalties.

Who counts as a small producer under packaging EPR in the UK?

If your business has a turnover between £1 million and £2 million and places between 25 and 50 tonnes of packaging on the UK market each year, you are classified as a small producer under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. Both thresholds must apply. Businesses that exceed both the turnover and tonnage thresholds are classified as large producers and face a different, more onerous set of obligations and reporting requirements, including waste management fee payments.

The table below breaks down the different producer categories based on annual turnover and the amount of packaging placed on the UK market.

This distinction matters. The guidance you read online and the advice you receive from a compliance partner should all be specific about which category applies to you. Conflating the two is one of the most common sources of confusion in the market right now.

What has changed and why it matters

Packaging EPR replaced the previous packaging regulations, which had been in place since 1997.  The new regulations set two categories for producers (Small Producers and Large Producers), require significantly more detailed and more frequent data reporting, and require large producers to pay the costs of managing packaging waste from household as well as continuing to purchase packaging recovery notes (PRNs). For large producers costs under the new regulations are significantly greater – making the packaging data which drives the system a more business critical issue.

Unlike large producers, small producers are not required to pay EPR waste management fees.

Large or small, all producers must register with the relevant environmental regulator, submit accurate packaging data and report by nation of sale.  For small producers, this is a significant step change with many encountering detailed compliance requirements for the first time.

The key obligations for small producers in 2026

Under the 2024 Regulations, small producers must:

• Register with the relevant environmental regulator (the Environment Agency in England, SEPA in Scotland, Natural Resources Wales, or NIEA in Northern Ireland) via the government's Report Packaging Data (RPD) service by 1 April each year. Failure to register by this deadline can result in civil sanctions, fines and, in serious cases, criminal prosecution.
• Submit packaging data by material type (paper, fiber-based composite, glass, steel, aluminium plastic, wood, other) weight in kilograms and packaging class (primary, secondary, shipment or transit).
• Classify all packaging as either household or non-household. Household packaging is packaging that is likely to be disposed of by consumers at home or end up in household waste. Non-household packaging is used in commercial, industrial or agricultural settings.
• Report by nation of sale across England, Scotland, Wales and Northern Ireland.

One important nuance on nation of sale reporting: the Environment Agency has issued a Regulatory Position Statement confirming that enforcement of nation of sale reporting for England will not begin until 2027. Producers are still expected to collect and retain this data in 2026, but will not normally face penalties for failing to submit it for England specifically. The position for Scotland, Wales and Northern Ireland may differ, and producers should check with the relevant regulator.

Joining a compliance scheme: optional but worth considering

Small producers are not legally required to join a compliance scheme and can be made directly with the environmental regulator. However, joining an approved scheme reduces the annual registration fee from approximately £1,216 to £631, and they will provide access to expert guidance, data management support and ongoing compliance assistance. For businesses without dedicated compliance resource, the practical value of scheme membership often outweighs the cost difference.

Where small producers are getting it wrong

The challenge for small producers is rarely a lack of willingness. Most businesses want to comply. The difficulty lies in understanding what compliance actually requires and in having the internal resources to deliver it accurately.

Common pressure points include:

• Threshold confusion: applying the criteria to complex supply chains is not always straightforward, particularly for businesses that import, manufacture and distribute across multiple channels.
• Inaccurate data submission: errors in material classification, even unintentional ones, can result in incorrect fee calculations and regulatory scrutiny.
• Household vs. non-household misclassification: this is one of the most frequent sources of error
• Nation-of-sale data gaps: businesses that have not yet built processes to capture where packaging is sold will face difficulties when full enforcement begins.

At ERP UK we speak to small producers every week who are surprised by the level of detail now required. The most common misconception is that being a small producer means minimal obligations or reporting requirements. Getting the data right from the outset is far easier than trying to correct it under pressure.

Compliance as a business opportunity

Approached strategically, packaging EPR compliance can become a beneficial process; mapping packaging flows, classifying materials and recording nation-of-sale data creates a clearer picture of how packaging moves through your business. That visibility has value beyond compliance. It supports procurement decisions, sustainability reporting and supplier conversations.

Businesses that engage early, build good data habits and understand their obligations fully are the ones that avoid last-minute corrections, penalty risk and reputational exposure.

How ERP UK supports small producers

ERP UK works with small producers to make packaging EPR compliance manageable from day one. We help businesses confirm whether they meet the threshold criteria, register with the appropriate regulator and structure their packaging data correctly. Our team guides producers through the household and non-household distinction, supports accurate nation of sale reporting and helps identify gaps before they become problems.

We do not offer a one-size-fits-all service. All producers have different supply chains, different packaging profiles and different internal capabilities. Our role is to understand your specific situation and provide the support that fits it, whether that is hands-on data management, expert guidance or a structured compliance review.

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About ERP UK

ERP UK helps businesses take the complexity out of environmental compliance. Whether you're navigating WEEE, batteries or packaging regulations for the first time or managing ongoing obligations, our compliance specialists combine practical advice with robust data management to help you report accurately, meet deadlines and stay ahead of changing legislation.

To learn more about ERP UK and our services please visit our About page

Telephone: +44 (0)20 3142 6452

E-mail: uk@erp-recycling.org

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