EPR plastics compliance, without the spreadsheet headache.

Extended Producer Responsibility (EPR) is the UK regulatory regime that makes producers financially and physically responsible for the entire lifecycle of the packaging they place on the UK market, especially its end-of-life disposal and recycling. It replaces the old Producer Responsibility Obligations regime that ran since 1997. Large producers began reporting under the new rules in 2023, with full modulated fees applying from 2025 onward.

EPR applies if your UK turnover is above £1M and you place more than 25 tonnes of packaging on the UK market per calendar year. The two thresholds are combined: below £1M turnover, or 25 tonnes or fewer of packaging, you are out of scope. Above the threshold you are either a small producer (see next question) or a large producer. Large producer status applies if your UK turnover is above £2M and you place more than 50 tonnes of packaging per year — large producers have full biannual reporting and modulated fee obligations. Group structures: each subsidiary’s figures generally count separately, with some exceptions for shared-brand groups.

You are a small producer if either: (a) your UK turnover is between £1M and £2M and you place more than 25 tonnes of packaging on the UK market per calendar year, or (b) your UK turnover is more than £2M and you place between 25 and 50 tonnes of packaging on the UK market per calendar year. Small producers have lighter obligations than large producers: data submission once per year (rather than twice), basic recyclability classification by material, and a Plastic Packaging Tax liability check. Modulated fees do not currently apply at the small-producer tier. Our EPR Starter package is built specifically for this group, with a single annual data pack prepared and reviewed for you.

Modulated fees are EPR’s way of charging more for harder-to-recycle packaging. Each material category (plastic, glass, paper, metal, fibre-based composite, wood) has a base fee per tonne; the fee is then "modulated" up or down based on how recyclable the packaging is in practice (the RAM, or Recyclability Assessment Methodology, score). Easily recyclable mono-material packaging pays less. Multi-layer films, black plastic, contaminated formats pay more. Fees flow into a national pot used to fund kerbside collection.

Two filings a year for large producers. H1 covers January to June, due 1 October. H2 covers July to December, due 1 April. Small producers file once a year. Plastic Packaging Tax filings are quarterly. Late or inaccurate filings can trigger penalties up to £200,000 or 10 percent of UK turnover, whichever is greater.

PPT is a separate HMRC-administered tax of £223.69 per tonne (2025 rate) on plastic packaging containing less than 30 percent recycled content. EPR is the broader Defra regime covering all packaging materials, recyclability assessment, and producer fees flowing to local authority recycling. Most producers are obligated under both. Our Standard and Pro tiers cover both regimes in one service so you do not file each separately.

DRS is a separate but related scheme requiring producers of in-scope drinks containers (PET plastic bottles, aluminium and steel cans) to add a refundable deposit at point of sale, recovered when consumers return the empty container. Implementation is staggered: Scotland was first, England and Northern Ireland are scheduled for late 2027. EPR Pro includes DRS readiness for any client placing drinks containers on the market.

Twelve months of SKU data: product list, packaging components per SKU (with weights), material composition, units sold into the UK market. Most clients have this in their ERP or PIM system. We provide a structured intake template if not. For PPT we also need recycled-content evidence from your packaging suppliers.

Yes, often materially. Switching from black PET to clear PET, removing labels that contaminate recyclate, moving from mixed-material laminates to mono-material formats, lightweighting glass, can all cut your modulated fee by 20 to 50 percent. EPR Pro includes an annual fee-reduction roadmap with concrete packaging changes ranked by ROI.

Defra and the Environment Agency can issue civil penalties up to £200,000 or 10 percent of UK turnover (whichever is greater) for non-registration, late filing, or materially inaccurate data. They can also publish your name on a public non-compliance list. Our Standard and Pro tiers include full data preparation, internal review and deadline reminders against every Defra cycle so your submission is ready well in advance and never late.

No, and that is by design. Offset Britain is not a registered compliance scheme. Under UK EPR rules, only the obligated producer (or a Defra-approved compliance scheme) can submit through the National Packaging Waste Database. What we do: prepare a fully-reviewed, audit-grade data pack with your packaging breakdown, RAM classification, modulated fee calculation and PPT figures, ready for you to enter into your Defra portal account. We walk you through the submission step by step on your first cycle so it is fast and accurate. Most clients find the actual portal entry takes under thirty minutes.