Check if you must comply with EPR for packaging
Summary
The Environment Agency has published guidance explaining how businesses should determine whether they are obligated under extended producer responsibility (EPR) for packaging. It sets out who counts as a packaging producer, how group thresholds are assessed, and the reporting basis for 2026 packaging data.
Why it matters
Residential property surveyors and related firms may need to assess whether any packaging they supply or import brings them within EPR obligations. The guidance is relevant for compliance planning, particularly for businesses operating as part of a UK group or using packaged goods in their operations.
Key points
- All businesses must check whether they are a producer of packaging under EPR.
- Obligations depend on packaging activities, turnover and packaging volumes, with group-level tests applying to UK-established corporate groups.
- For 2026 reporting, packaging data is calculated from 1 January 2025 to 31 December 2025.
- Charities are exempt, but not charity subsidiaries trading for profit.
- The guidance references detailed definitions and examples in the regulations and National Packaging Waste Database.
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