Are you in scope?

Under extended producer responsibility (EPR) for packaging, every UK organisation that handles packaging should check whether it is a producer and, if so, whether it is an obligated producer.

Step 1. Do you carry out a 'packaging activity'?

GOV.UK lists these activities:

• supplying filled packaging under your own brand;
• packing goods or filling packaging;
• importing goods in packaging;
• supplying unfilled packaging that you manufacture or import;
• hiring or loaning out reusable packaging;
• owning an online marketplace through which filled or unfilled packaging is supplied in the UK from outside the UK;
• selling filled packaging to an end user (consumer or business).

You can still be the producer if another business imports, packs or manufactures goods in your branded packaging for you.

Step 2. Do all three conditions apply?

According to GOV.UK, you are an obligated producer if you carry out a packaging activity and all of these apply:

1. you are an individual business, subsidiary or corporate group established in the UK;
2. you supplied or imported more than 25 tonnes of packaging in the UK in the previous calendar year;
3. your worldwide annual turnover was £1 million or more.

Which year's figures?

For 2026 packaging data, GOV.UK says to count packaging supplied or imported from 1 January to 31 December 2025, and to take turnover from the last accounts available before 7 April 2026 (audited accounts if you publish them).

'Established in the UK'

This means your registered office, head office or principal place of business is in the UK (including a business run from home). A business with a head office abroad can still count as established in the UK if it has a UK branch, warehouse, or a UK PO box, returns or other postal address.

What counts as packaging?

Broadly, any material used to contain, protect, handle, deliver or present goods to an end user, including pallets, display units and items designed to be filled at the point of sale, such as coffee cups. Count each item of packaging only once, even if you carry out several activities on it.

Exemptions and edge cases

• Charities supplying or importing packaging are exempt (but not their trading subsidiaries run for profit).
• If you import or pack goods for a large producer in their branded packaging, the brand owner is usually the obligated producer.
• Groups are tested together: see groups and subsidiaries.

Next: small or large producer?