Important Information Ahead of 1 April pEPR Deadline
The Foodservice Packaging Association (FPA) recently held a joint webinar with the Environment Agency on pEPR which demonstrated the level of information required for pEPR reporting.
As a final reminder, 1 April is the deadline for:
1. All organisations responsible under EPR must register with environmental regulators and pay the associated fee. Organisations that register after this deadline will have to pay a late fee of £332, on top of normal registration fees, and could be subject to enforcement action being taken.
2. Large organisations, which report data every six months, must submit data covering the period from 1 July to 31 December 2024.
3. Small organisations must submit data for the full calendar year 1 January 2024 to 31 December 2024.
A summary of the points raised by the EA are detailed as follows:
Reporting data under EPR: an overview
• Reporting and Payment Responsibility. If you cannot provide evidence that your packaging is exempt – such as proof that it was exported or delivered to large businesses – you must report and pay for all of it. The responsibility is on you to obtain this information from your customers or other relevant parties. If you cannot verify that another party has reported the packaging, you are liable for the payment.
If you have evidence supporting exemptions, you must maintain records and make them available for inspection.
• Turnover and Registration. The financial turnover threshold for registration includes all UK trading activity, including your exports – however, packaging that is exported is exempt from EPR payments.
• Packaging Given Free of Charge. Even if packaging is provided at no cost – such as for food service in schools, hospitals and prisons – it must still be reported. Additionally, in the case of these institutions, the EPR responsibility falls on the packaging supplier as they are not classed as large producers.
• Packaging in Closed Environments. All packaging must be reported, even if used in closed environments where waste is collected by commercial waste collectors rather than households. This packaging is still subject to EPR fees.
• Franchise Operations. UK-registered franchisors must report and pay for all packaging, even if it is supplied directly to franchisees that do not qualify as large businesses. If the franchisor is not registered in the UK, they cannot register for EPR, and the responsibility to report and pay shifts to the packaging supplier.
• Online vs. Physical Stores. Online retailers (web shops) are subject to the same EPR obligations as physical stores.
• Branding Considerations. Unmarked packaging combined with a branded sleeve is considered a branded product. However, a code on the base of the packaging, such as an FSC certification mark, does not make the item a brand.
• Binned Litter List. Packaging listed under “binned litter” is subject to EPR fees, even if it ultimately ends up in homes or is commercially managed. This includes packaging used in vending machines within commercial premises handling their own waste. Even if provided at no cost, it must still be reported.
• Data Sharing. The Environment Agency (EA) confirmed that while data is shared with other government departments, it is aggregated and anonymized. They are currently determining whether aggregated data is shared with HMRC.
You can find all the relevant pEPR links here:
Producer recycling obligations and disposal fees
Extended producer responsibility for packaging: register and pay the fee
UK Joint policy statement
Packaging data: how to create your file for extended producer responsibility – GOV.UK
Important change to EPR guidance
Please also be aware the above ‘Packaging data: how to create your file for extended producer responsibility’ was updated on 25 March 2025 as it contained an error.
The guide incorrectly stated that small producers (small organisations) must submit recyclability data from January 2026. Small producers are not required to report this data.
Environment Agency action on freeriders
• The Environment Agency (EA) is actively pursuing businesses that have not registered for EPR or failed to submit packaging data.
• More staff are being hired to track down non-compliant businesses using an “intelligence-led approach.”
• The EA is comparing the list of obligated producers for PRNs against businesses submitting EPR data.
• This effort has led to over 1,000 businesses joining EPR, though 270 have legitimately dropped out of the PRN register.
• While EA’s enforcement efforts are increasing, some businesses still appear on the register briefly before disappearing.
• The EA are constantly requesting information to be shared on suspected freeriders so the crackdown can continue.