Turnover under £1 million?

Short answer: on GOV.UK's threshold grid, a business with annual turnover of £1 million or less has no obligation under packaging EPR, however much packaging it handles. You don't register, report or pay a fee.

But "turnover" here has a specific meaning, and a few situations catch people out.

1. It's worldwide turnover

The test uses your worldwide annual turnover, not just UK sales.

2. Groups use group totals

If you're part of a corporate group, the holding company must add up the figures for all UK-established group companies that supply or import packaging. Turnover of group companies that don't supply or import packaging is left out. If the group is over the threshold, every member is obligated, even if each company's own turnover is under £1 million. See groups and subsidiaries.

3. Use the right accounts

For 2026 packaging data, GOV.UK says to take turnover from the last accounts available before 7 April 2026. If you publish audited accounts, you must use those. If you don't have to file audited accounts, use whatever accounts are available.

4. Re-check every year

The test is re-run each year. Growth can bring you into scope. If you're already registered and stop being a producer, GOV.UK's February 2026 update says you must tell the regulator within 28 days.

5. Exactly £1 million

Other rules that can still apply

• Your customers may ask for data. GOV.UK notes that responsibility for packaging can change depending on whether you sell it to a large producer or a small one. A larger customer may ask what packaging you supply.
• Plastic Packaging Tax is separate. HMRC's tax has no turnover test. You must register if you manufacture in or import into the UK 10 tonnes or more of finished plastic packaging components in 12 months (or expect to in the next 30 days). From 1 April 2026 the rate is £228.82 per tonne on packaging with less than 30% recycled plastic.
• Charities that supply or import packaging are exempt from EPR for packaging, but their trading subsidiaries are not.

Quick answers

Do I need to register for packaging EPR if my turnover is under £1 million?

Not usually. On GOV.UK's threshold grid, annual worldwide turnover of £1 million or less means no obligation under packaging EPR, whatever your packaging tonnage. If you are part of a corporate group, use group totals.

Which turnover figure do I use for packaging EPR?

Worldwide annual turnover. For 2026 packaging data, GOV.UK says to use the last accounts available before 7 April 2026, and audited accounts if you publish them.

Does Plastic Packaging Tax have a turnover threshold?

No. You must register for Plastic Packaging Tax if you manufacture in or import into the UK 10 tonnes or more of finished plastic packaging components in 12 months, or expect to in the next 30 days.