UK organisations that use plastic packaging may need to comply with two distinct pieces of legislation: Extended Producer Responsibility (EPR) obligations and the Plastic Packaging Tax (PPT).
The common aim of these regulations is to ensure that businesses recognise and pay for the negative externalities of plastic waste and to incentivise reduced and/or circular use of plastics. But they are distinctly different obligations.
Let’s take a closer look.
What is Extended Producer Responsibility (EPR)?
EPR legislation shifts the financial burden of managing packaging waste from consumers and local taxpayers to the businesses that produce or import it, an application of the “polluter pays” principle. EPR applies to plastic and other packaging materials including paper, glass, metal and wood. The Environment Agency oversees the EPR scheme through PackUK and requires reporting by businesses with an annual turnover of £1 million or more that introduce more than 25 tonnes of product packaging per year into the UK. Organisations that meet these thresholds are required to submit detailed packaging information once or twice per year (depending on the size of the organisation) and pay for their usage of packaging materials via the purchase of Packaging Waste Recovery Notes (PRNs) or Packaging Export Recovery Notes (PERNs).
What is the Plastic Packaging Tax (PPT)?
PPT is a levy on non-recycled plastic packaging imported into or manufactured in the UK. It officially came into effect 1 April, 2022 and is administered by HMRC. It applies to businesses that manufacture or import 10 tonnes or more of virgin plastic packaging over a 12-month period. Plastic packaging that has 30% or more recycled content is exempt from the tax. Reporting of plastic packaging usage data and payment is required quarterly.
How much do organisations need to pay?
EPR for packaging base fees vary by material and their recyclability. Plastic packaging currently attracts one of the highest fees of £423 per tonne. The latest base fees are listed on the UK EPR website. EPR fees will be modulated for 2026-2027 based on a to-be-published Recyclability Assessment Methodology (RAM) rating that aligns fees with the recyclability of packaging materials.
PPT rates are reviewed annually. In the 2025 Budget, the government announced a PPT rate rise in line with the Consumer Price Index (CPI). Effective 1 April 2026, the rate increased from £223.69 per tonne to £228.82 per tonne.
Is it possible to streamline reporting for these two regulations?
As the requirements of EPR and PPT are different, organisations may be obligated under one, the other, or both schemes and required to collect and report separately on different types of data. But maintaining comprehensive records of packaging material composition, weight, origin, and other data is essential to meet all legislative reporting requirements, and there are synergies possible when packaging data collection is well aligned.
Understanding packaging choices and opportunities to reduce fees can be a powerful incentive to change. Sustainable strategies that lower costs and benefit the environment include switching to easily recyclable materials, reducing packaging weight, and increasing recycled content.
Need help?
Grain and Menzies ESG provide cross-sector support in legislative compliance together with deep expertise in UK tax rules and obligations. We can help your business understand and comply with plastic packaging legislation and build packaging management into your sustainability strategy.
