Groups and subsidiaries
Why group totals, not each company's own figures, can decide whether each company is a small or large producer.
GOV.UK says a holding company must check whether its corporate group is obligated, using totals for all UK-established group companies that supply or import packaging:
- total weight of filled or unfilled packaging supplied or imported into the UK;
- total worldwide annual turnover (excluding group companies that do not supply or import packaging).
If the group totals meet the large-producer criteria, every member is a large producer; if small, every member is small, regardless of each company's own figures.
The amended fee schedule includes separate per-subsidiary charges for group registrations. The regulators' 'agreed positions and technical interpretations' guidance (on the National Packaging Waste Database) has worked examples.
Sources
Checked 17 October 2026. We summarise official material in our own words. The originals take precedence.