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WHAT IS EPR? AN INTRODUCTION TO EXTENDED PRODUCER RESPONSIBILITY
Written by
LIAM BLAND
SUSTAINABILITY
Table of Contents
INTRODUCTION
Extended Producer Responsibility (EPR) has become one of the most talked-about packaging regulations in the UK. If you’re hearing about EPR from suppliers, in industry news, or from your compliance team, you’re probably wondering what it means for your business—and more importantly, whether it affects the packaging materials you use daily.
The good news? If your business primarily uses load stability products like pallet wrap, stretch film, and protective packaging materials, EPR likely won’t directly impact your costs. But understanding the basics will help you navigate conversations with suppliers and ensure you’re making informed packaging decisions.
WHAT IS EXTENDED PRODUCER RESPONSIBILITY?
Extended Producer Responsibility is a regulatory framework that makes businesses financially responsible for managing the packaging they place on the UK market. Instead of local councils bearing all the costs of collecting, sorting, and recycling packaging waste, EPR shifts these expenses to the companies that supply packaged goods to consumers.
Think of EPR as the government’s way of saying: “If you’re putting packaging into the system, you should help pay for dealing with it at the end of its life.” The system launched in the UK in 2023, following successful implementations across Europe.
The principle is straightforward – encourage businesses to use less packaging, choose more recyclable materials, and reduce the environmental impact of packaging waste. Companies now pay fees based on the amount and type of packaging they place on the market, with the money going to local authorities to cover waste management costs.
The Key Point: Household vs Non-Household Packaging
Here’s where it gets interesting for your business. EPR primarily targets what’s called “household packaging”- packaging that ends up in domestic bins and needs to be collected from homes by local councils.
Household packaging includes things like:
- Retail product packaging that consumers take home
- Food packaging from supermarkets
- Online shopping boxes delivered to homes
- Consumer goods packaging
Non-household packaging includes:
- Pallet wrap used for transporting goods between businesses
- Protective packaging used in warehouses and distribution centres
- Tertiary packaging that never reaches consumers
- Industrial protective materials
This distinction is crucial because EPR fees only apply to household packaging. The protective packaging materials you use – pallet wrap, stretch film, load stability solutions – are classified as non-household packaging and are exempt from EPR fees.
WHY LOAD STABILITY PRODUCTS ARE DIFFERENT
Pallet wrap and similar load stability products fall into a category called “tertiary packaging.” This packaging is used specifically for transport between businesses and doesn’t typically end up in household waste streams.
When you wrap pallets for storage or transport, that material stays within the commercial supply chain. It’s removed at warehouses, distribution centres, or retail premises—not at consumers’ homes. Because local authorities don’t collect this type of packaging from households, it’s not subject to EPR fees.
This means that for most businesses using standard load stability solutions:
- No EPR fees apply to your pallet wrap usage
- No additional compliance costs for this type of packaging
- No changes needed to your current packaging processes
DOES EPR AFFECT YOUR BUSINESS AT ALL?
While EPR might not affect your pallet wrap costs, it could impact your business in other ways:
If you package goods for retail sale – Any packaging that goes home with consumers (product boxes, protective packaging around consumer goods, retail packaging) will be subject to EPR fees.
If you’re a large organisation – Companies with £2+ million turnover and over 50 tonnes of packaging annually must report all their packaging usage, including non-household packaging like pallet wrap, even though fees don’t apply.
If you import goods – Importing packaged products makes you responsible for EPR obligations on any household packaging involved.
Most businesses will find their load stability and protective packaging costs remain unchanged under EPR, while any consumer-facing packaging may see cost increases.
What About Other Packaging Regulations?
While EPR might not affect your pallet wrap costs, there’s another regulation that could: the Plastic Packaging Tax.
This separate tax applies to plastic packaging (including pallet wrap) that doesn’t contain at least 30% recycled content. At £223.69 per tonne, this tax is more likely to impact your protective packaging costs than EPR.
The Plastic Packaging Tax affects all plastic packaging, regardless of whether it’s household or non-household. So while your pallet wrap is exempt from EPR fees, it could still be subject to this tax unless it meets the recycled content threshold.
THE EPR FEE STRUCTURE
Even though these fees don’t apply to many of the products we sell, it’s worth understanding the EPR cost structure to see why the exemption matters:
- Plastic packaging: £485 per tonne
- Cardboard and paper: £215 per tonne
- Steel: £305 per tonne
- Wood: £320 per tonne
For a business using 30 tonnes of plastic packaging annually, EPR would represent over £14,500 in additional costs. The exemption for tertiary packaging like pallet wrap saves businesses significant money.
Why This Exemption Makes Sense
The logic behind exempting tertiary packaging from EPR is practical. Local authorities don’t collect pallet wrap from households because it never gets there. The costs EPR covers – kerbside collection, household waste sorting, municipal recycling facilities – don’t apply to commercial packaging materials.
Instead, businesses typically arrange their own commercial waste collection for materials like used pallet wrap, or work with specialist recyclers. This separate commercial waste stream doesn’t create costs for local authorities, so it’s not included in EPR.
COMPLIANCE STILL MATTERS
While EPR fees don’t apply to things like your pallet wrap usage, some compliance requirements might still affect larger businesses:
Reporting requirements – Large organisations must still report their tertiary packaging usage, even though no fees apply.
PRN requirements – Packaging Recovery Notes (PRNs) are still required for non-household packaging, continuing previous regulations.
Record keeping – Maintaining accurate records of packaging usage remains important for regulatory compliance.
Making Smart Packaging Choices
Understanding EPR helps you make better packaging decisions across your entire operation:
For load stability products – Focus on efficiency and performance since EPR fees don’t apply. However, consider the Plastic Packaging Tax benefits of choosing materials with 30%+ recycled content.
For consumer-facing packaging – EPR costs make material selection more important. Lighter materials and recyclable options could reduce fees.
For overall strategy – Knowing which regulations apply to which packaging helps you prioritise your compliance efforts and budget appropriately.
THE FUTURE OF PACKAGING REGULATIONS
EPR will evolve over time, with modulated fees from 2026 that reward more recyclable packaging. However, the fundamental distinction between household and non-household packaging is unlikely to change.
This means your load stability and protective packaging will likely remain exempt from EPR fees, while the focus continues on packaging that creates costs for local authorities through household waste collection.
Whether it’s EPR, PPWR or taxes; our finger is always on the pulse to keep you informed of any regulations that could affect your packaging operations.
LIAM BLAND
MARKETING MANAGER
CONCLUSION
Working with Your Packaging Supplier
As packaging suppliers with our finger on the pulse, we’re able to help you navigate these regulations and understand which materials are affected by which rules. We can also help you identify opportunities to reduce costs through smart material choices, particularly around the Plastic Packaging Tax.
So feel free to reach out and get in touch by using the contact buttons throughout the website.
Key takeaways
- EPR targets household packaging that creates costs for local authorities, not commercial packaging materials
- Pallet wrap and load stability products are exempt from EPR fees as they’re classified as non-household tertiary packaging
- Your protective packaging costs likely won’t increase due to EPR, though other regulations like Plastic Packaging Tax might apply
- EPR may affect other packaging if you supply goods directly to consumers or use retail packaging
- Large businesses still need to report all packaging usage, even exempt materials, for compliance purposes
- Commercial waste arrangements continue as before for materials like used pallet wrap
- Focus your compliance efforts on understanding which regulations apply to which parts of your packaging usage
- Stay informed about changes but don’t panic about EPR affecting your core load stability packaging needs
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