UK packaging EPR for sellers outside the UK
9 min read
UK packaging EPR for sellers outside the UK: why you are not the producer, who reports instead, when a UK address changes that and what data buyers need.
You make products outside the UK and sell them to customers in Great Britain or Northern Ireland, through a marketplace, a UK distributor or your own web shop. Since 1 January 2025, UK packaging EPR (extended producer responsibility for packaging) has required producers to report their packaging and, once they are large, to meet recycling targets and pay fees on household packaging. Unlike the EU, the UK has no representative for this: only businesses established in the UK can be producers. Here is who carries the duty instead, what can make you a producer and what your UK customers need from you.
UK packaging EPR in brief: who counts as a producer
EPR makes businesses that put packaging on the market pay for it once it becomes waste. In the UK, the rules are in the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (opens in a new tab) (SI 2024/1332). They apply in England, Wales, Scotland and Northern Ireland alike (regulation 1(4)).
A business is a producer only if it is established in the UK, belongs to one of seven classes (such as brand owner, importer, online marketplace operator or seller to the final user) and performs that function in the UK in the course of business (regulation 15(1) (opens in a new tab)).
Why there is no UK representative for packaging
In the EU, a producer that supplies packaging or packaged products directly to end users in a member state where it is not established must appoint an authorized representative for EPR there (Article 45(3) of the Packaging and Packaging Waste Regulation (EU) 2025/40 (opens in a new tab), PPWR). Member states may require one from every producer outside the EU. A Commission proposal to suspend this rule, COM(2025) 982, had not been adopted as of 20 October 2026; for Germany, see PPWR authorized representative in Germany.
The UK Regulations contain no representative role: the duties go to a business in the UK that handles your goods, not to you.
A "UK Responsible Person" does not fill this gap either; British law uses that title for cosmetics and medical devices (UK Responsible Person: when you need one). For the EU roles, see our comparison of representative roles.
Who is the UK packaging producer, route by route
The answer depends on how your goods reach UK customers:
| How you sell into the UK | Producer for your packaging | SI 2024/1332 |
|---|---|---|
| Online marketplace, no UK establishment | The marketplace operator, if established in the UK | Reg. 10(5), 20(2), (4) |
| Sale to a UK business customer, whoever handles customs | That customer, as importer | Reg. 18(1)(a), (2), (3)(a) |
| Your UK group company imports and sells your brand | The UK group company, as brand owner | Reg. 16(1)(b) |
| Own web shop, shipped from abroad to UK consumers | None, on our reading of the wording: consumers do not act in the course of business | Reg. 15(1)(a), (c)(ii), 18(1)(a) |
| You have a UK postal address, returns address or warehouse | You may be, as brand owner, importer or seller | Reg. 4(1)(c), 15 to 22 |
A UK producer has duties only above the thresholds, so a small UK buyer may have none (regulation 25(1)).
Thresholds, deadlines and PackUK fees
A small producer had a turnover of more than £1 million and supplied more than 25 tonnes of packaging in the UK; a large producer more than £2 million and 50 tonnes (regulation 24 (opens in a new tab)). For 2027, that is the last financial year ending before 7 April 2026 and the packaging supplied in 2025. The government guidance counts worldwide turnover (gov.uk (opens in a new tab)).
| Duty | Small producer | Large producer | SI 2024/1332 |
|---|---|---|---|
| Register with the environmental regulator | By 1 April of the year | By 1 October of the year before | Reg. 25(1), 28(1) |
| Report packaging data | Yearly, by 1 April | Every six months, by 1 October and 1 April | Reg. 35, 36 |
| Meet recycling targets with recycling notes | No | Yes | Reg. 25(2), 40 |
| Pay disposal and administration fees | No | Yes, if it supplied household packaging the year before | Reg. 60, 68 |
Large producers that only sell to final users register by 1 April and owe no recycling target or fees (regulations 25(2), 28(1)(b)(ii), 60(1)). For 2027, other large producers had to apply by 1 October 2026; small producers apply by 1 April 2027. Anyone who becomes a producer after the deadline and is not in a compliance scheme applies within 28 days (regulation 28(3)(a)).
Fees go to PackUK, the scheme administrator, and are calculated only on household packaging, mainly primary packaging and shipment packaging to consumers (regulations 8, 61). PackUK issued the first notices of liability in October 2025. As of 5 October 2026, it intended to issue those for April 2026 to March 2027 by the end of November 2026 (PackUK operational plan 2026 to 2027 (opens in a new tab)).
What your UK customers need from you
Your UK buyer can only report what you tell it. Expect requests for:
- Material and weight of each component, such as box, window and insert, in kilograms, with plastic marked rigid or flexible for household packaging (regulation 7(7); Schedule 4, paragraphs 1 and 2; gov.uk (opens in a new tab)).
- Packaging class: primary (the sales unit), secondary (a grouping of sales units), tertiary (transport) or shipment packaging to consumers (regulation 7; Schedule 4, paragraph 5).
- Household or business use, which decides whether fees apply (regulation 8).
- Design details for the recyclability assessment that fee-paying large producers carry out under PackUK's methodology (regulations 25(3), 26).
- Brand and import details, which decide who the producer is (regulations 16, 18).
Five steps for sellers outside the UK
- Map your sales routes and who first owns the goods in the UK (regulations 18, 20).
- Check every UK address: a PO box, returns address, warehouse or branch makes you established there (regulation 4(1)(c)).
- If you are established, test the thresholds with your worldwide turnover and register on time (regulations 24, 28).
- Build a packaging specification per product: components, materials, weights, class and household or business use.
- Agree the data flow in writing with UK importers: which figures, in what format, before their reporting dates of 1 October and 1 April (regulations 35, 36).
Example: a Japanese stationery brand
A Japanese company sells notebooks in the UK on three routes. On a UK marketplace, the operator is the producer (regulation 20(2)). A UK retail chain imports them itself and, as importer, asks for weights per component (regulation 18). The brand's web shop ships from Japan to UK consumers; on our reading of the Regulations, no one in the UK is the producer for that packaging.
To speed up returns, the company plans a UK returns address. That address makes it established in the UK (regulation 4(1)(c)): the marketplace stops being the producer for its goods (regulation 20(4)), and the company itself can become the producer, for example as brand owner, with duties once it passes the thresholds.
Common mistakes with UK packaging EPR
- Looking for a UK representative for packaging. The Regulations have none (regulation 15(1)(a)).
- Opening a UK returns address without checking EPR. It ends the marketplace's role as producer (regulations 4(1)(c), 20(4)).
- Sending rough estimates instead of weights. Producers report actual weights in kilograms (Schedule 4, paragraph 1(1)).
- Treating UK and EU packaging EPR as one project. PPWR registration runs member state by member state (Article 44(2)), with its own representative rule; a UK registration does not cover it, and vice versa.
Conclusion: not the producer, but part of the chain
Without a UK establishment, you are not a producer under UK packaging EPR, and no representative can register for you. The marketplace or your UK buyer carries the duty and depends on your data. A UK address changes this, so check before you open one.
Representa supports packaging compliance under the PPWR and UK packaging EPR through Packaging, EPR & Sustainability; planning which sales route triggers which duty belongs to Consulting.
Frequently asked questions
Do I need a UK representative for packaging EPR?
No. Only a business established in the UK can be a producer under SI 2024/1332 (regulation 15(1)(a)), and the Regulations provide for no authorized representative. The duty falls on the marketplace operator or the UK business that imports or first owns your goods, if it passes the thresholds.
Does a UK returns address make me a producer?
It makes you established in the UK: regulation 4(1)(c) covers a UK postal address, and gov.uk guidance names returns addresses expressly. You can then become a producer for the packaging you handle as brand owner, importer or seller, with duties once you pass the thresholds in regulation 24.
Do small producers pay PackUK fees?
No. Disposal and administration fees are payable by producers that were large producers in the previous calendar year, other than pure sellers, and supplied household packaging (regulation 60(1)). Small producers register and report packaging data once a year (regulations 25(1), 36).
Does UK packaging EPR apply in Northern Ireland?
Yes. SI 2024/1332 applies in England, Wales, Scotland and Northern Ireland (regulation 1(4)). The appropriate agency in Northern Ireland is DAERA, the Department of Agriculture, Environment and Rural Affairs (regulation 5(1)(d)); gov.uk names the Northern Ireland Environment Agency as the regulator to contact there.
Does my EU PPWR authorized representative cover the UK?
No. The representative under Article 45(3) of Regulation (EU) 2025/40 acts in an EU member state. The UK has its own regime without a representative role, so check the UK sales routes separately.
