Independent guide. Not affiliated with Defra, PackUK or any UK regulator. Not legal advice. Disclaimer
Guide

Small or large producer?

How turnover and packaging tonnage decide whether you are a small or large producer, and why it matters for fees.

Reviewed 17 October 20263 official sources

If you are obligated, you are either a small or a large producer. GOV.UK sets this out in a simple grid:

Packaging supplied/imported (previous year)Turnover £1m or less£1m to £2mMore than £2m
Less than 25 tonnesNo obligationNo obligationNo obligation
25 to 50 tonnesNo obligationSmall producerSmall producer
More than 50 tonnesNo obligationSmall producerLarge producer

So a business is a large producer only if it has both more than £2 million turnover and more than 50 tonnes of packaging. The term 'small producer' has nothing to do with headcount.

What each type must do (summary)

Small producerLarge producer
Register with regulatorYes, each year (pay fee by 1 April)Yes, each year (pay fees by 1 October)
Report packaging dataOnce a yearEvery 6 months
Recycling obligations (PRNs/PERNs)NoYes, plus certificate of compliance
Household packaging waste disposal fees to PackUKNoYes
Recyclability (RAM) assessmentNo (per GOV.UK)Yes
Keep records7 years7 years

Sources

Checked 17 October 2026. We summarise official material in our own words. The originals take precedence.

  1. Check if you must comply with EPR for packaging (GOV.UK, Defra/EA; last updated 19 Aug 2026)
  2. EPR for packaging: what you must do as a 'small producer' (GOV.UK, Defra; last updated 19 Feb 2026)
  3. Deadlines for registration and packaging data reporting (GOV.UK, Defra; last updated 19 Aug 2026)