Extended Producer Responsibility (EPR) for packaging
Prepare your business for EPR packaging with our expert guidance on waste legislation, compliance and cost reduction strategies.
What is EPR Packaging?
Extended Producer Responsibility (EPR) for packaging is a policy framework designed to hold businesses accountable for the entire lifecycle of their packaging materials. This means that producers, brands, and retailers must ensure their packaging is designed for recyclability, responsibly managed after use, and contributes to the circular economy.
With 141 million tonnes of plastic packaging produced annually, packaging now accounts for 40% of global plastic waste, making it the single largest contributor to plastic pollution (OECD Global Plastics Outlook) (National Geographic). Without decisive action, plastic waste in our oceans could triple by 2040 (OECD Global Plastics Outlook) (National Geographic).
EPR packaging laws are now being introduced globally to reduce this impact and drive sustainable packaging innovations.
Affected parties of EPR packaging regulations
If your business manufactures, imports, distributes, or sells packaged goods, you are likely subject to EPR packaging compliance laws.
Affected parties include:
- Producers & manufacturers: Businesses creating packaging materials, particularly in food and beverage industries.
- Retailers & supermarkets: Responsible for ensuring their branded packaging meets EPR compliance to avoid penalties.
- Importers of packaged goods: Companies must ensure that international products adhere to local regulations.
- Online marketplaces: Accountable for managing packaging waste from goods sold on their platforms.
Failing to comply with EPR regulations can result in significant financial penalties, legal consequences, and reputational damage. Proactive compliance ensures businesses stay ahead of evolving legislation and contribute to a more sustainable world.
Reconomy helps turn compliance into a competitive advantage. Contact us today for a consultation.
Packaging activities in scope
Businesses engaged in packaging activities fall under various regulatory obligations based on their role in the supply chain.
Key activities related to EPR compliance include:
Companies that produce or sell goods under their brand name, even if they do not manufacture the packaging themselves, are considered responsible for that packaging’s compliance. They must ensure their packaging meets recyclability criteria, contribute to waste management schemes, and submit data on packaging usage.
Businesses that import packaged goods into a country with EPR regulations are responsible for ensuring compliance with local laws. This includes registering with national EPR schemes, reporting packaging data, and contributing to waste management funds.
Digital platforms selling packaged goods from multiple vendors are increasingly being held accountable for managing packaging waste associated with their products. Some jurisdictions require marketplaces to collect and submit packaging data on behalf of their sellers.
How we support
Reconomy provides tailored solutions to help businesses meet EPR packaging obligations across various activities:
- For branded goods suppliers: Through our Comply Loop brands, we assist in packaging data reporting, recyclability assessments, and compliance scheme registration.
- For importers: Our Comply Loop brands offer global compliance solutions, ensuring imported goods meet local regulations in multiple markets.
- For online marketplaces: We provide digital compliance tracking tools to streamline packaging data collection, supplier reporting, and financial contributions to EPR schemes.
Helping you find compliance schemes and PRNs/PERNs
Organisations can join registered compliance schemes to manage their EPR obligations. These schemes handle registration, data reporting, and recycling obligations. Packaging Recycling Notes (PRNs) and Packaging Waste Export Recovery Notes (PERNs) serve as evidence that companies meet recycling targets.
Navigating compliance schemes can be complex, but Reconomy simplifies the process by offering end-to-end support, including:
Scheme selection & registration
We help businesses identify the right compliance scheme based on their packaging obligations and assist with the registration process.
Data collection & reporting
Through our Comply Loop brands, we provide technology-driven solutions for tracking, managing, and submitting packaging data required for compliance schemes.
PRN/PERN acquisition & management
We ensure businesses obtain the appropriate PRNs or PERNs to meet recycling targets, reducing the administrative burden and financial risks.
Ongoing compliance support
Our experts monitor legislative changes and provide tailored guidance to keep businesses compliant with evolving regulations.
Nation-specific data submission requirements
Each country has distinct data reporting requirements that reflect national recycling practices. This ensures accurate compliance monitoring and alignment with country-specific waste management infrastructure.
Below are some key nation-specific data submission requirements:
United Kingdom
Businesses must provide detailed reports on the amount and type of packaging they place on the market. Data submissions include recyclability assessments, PRNs/PERNs acquisition, and nation-specific waste stream reports.
European Union
EU member states require companies to submit annual packaging waste data in alignment with the EU Packaging and Packaging Waste Directive. Reports must include material compositions, recycling rates, and compliance contributions.
France
Companies must register with an accredited Producer Responsibility Organisation (PRO) and report packaging placed on the market. France also mandates eco-modulation fees based on recyclability.
Germany
Businesses must register with the Zentrale Stelle Verpackungsregister (ZSVR) and submit detailed packaging declarations. Reporting includes waste classification, disposal methods, and financial contributions to recycling infrastructure.
United States
While EPR laws vary by state, regions like California, Maine, and Oregon have introduced mandatory reporting on packaging waste reduction, recyclability assessments, and compliance funding contributions.
Canada
Companies must comply with provincial EPR schemes requiring them to submit data on packaging materials, collection strategies, and financial contributions to waste management programs.
Other global markets
Countries such as Australia, India, and South Korea are enforcing stricter data reporting requirements, including producer fees, plastic reduction targets, and traceability of waste streams.
Failure to comply with these reporting obligations can lead to financial penalties and operational restrictions. Businesses must ensure they meet country-specific guidelines to maintain compliance and avoid regulatory risks.
For further country-specific guidance on EPR requirements, please reach out to one of our experts for a consultation.
Consultation and methodology for EPR packaging schemes
Governments and industry leaders to continue to collaborate to refine EPR frameworks, ensuring that regulations are practical, enforceable, and aligned with environmental targets.
The methodology behind EPR packaging compliance varies by country, with consultation processes shaping how businesses contribute to waste reduction and recycling efforts.
Country-specific consultation approaches:
The UK government engages with industry stakeholders through consultations led by the Department for Environment, Food & Rural Affairs (DEFRA). These discussions focus on PRN/PERN reform, recyclability assessments, and financial obligations for producers.
The European Commission oversees EPR-related policy consultations, ensuring alignment with the Circular Economy Action Plan. EU member states adapt directives locally, requiring businesses to stay informed of evolving national policies.
France’s EPR framework, managed by organisations like CITEO, includes extensive consultations with packaging producers to set eco-modulation fees based on recyclability.
The Central Packaging Register (ZSVR) regularly reviews compliance structures with stakeholders, including recyclability criteria and waste collection financing.
Consultation processes vary by province and state, with business forums and legislative reviews informing the development of EPR schemes in key markets like California and British Columbia.
The Australian Packaging Covenant Organisation (APCO) coordinates industry consultation to develop EPR policies that drive packaging design improvements and increase recycling rates.
By engaging in these consultations, businesses can influence regulatory decisions while preparing for compliance changes. Reconomy actively participates in discussions across multiple jurisdictions, ensuring our clients stay ahead of evolving EPR requirements worldwide.
Recyclability Assessment Methodology (RAM) and Packaging EPR
The Recyclability Assessment Methodology (RAM) is a critical framework designed to evaluate how effectively packaging can be recycled within existing waste management infrastructures. This methodology undergoes regular consultation to incorporate industry expertise, regulatory updates, and advancements in recycling technologies. Reconomy, through its Comply Loop brands, plays a significant role in supporting businesses with the RAM framework, ensuring they meet recyclability standards while optimising packaging sustainability.
Our brands contribute in the following ways:
Choosing the right third party compliance scheme
Many businesses rely on third-party compliance schemes to navigate EPR complexities. These schemes provide essential services such as; regulatory updates and data reporting, cost-efficient waste management solutions and risk reduction strategies to prevent penalties.
With multiple compliance schemes available, businesses must evaluate providers based on:
- Industry recognition
- Track record in managing EPR compliance
- Service offerings aligned with business needs
- Transparent pricing structures
Stay ahead of EPR packaging legislation with Reconomy
With regulations evolving rapidly, partnering with Reconomy ensures your business remains compliant, avoids penalties, and enhances sustainability performance.
Join leading global brands in turning compliance into a competitive advantage with Reconomy’s expert guidance. Contact us today to future-proof your packaging strategy and drive circular economy progress.
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FAQs
Here are some of the most frequently asked questions surrounding Packaging EPR and the required answers.
To comply with Extended Producer Responsibility (EPR) regulations, businesses must collect and report accurate packaging data. The process involves:
Identifying All Packaging Materials
Track the type and quantity of packaging used, including primary, secondary, and tertiary packaging.
Categorise materials by recyclability according to the Recyclability Assessment Methodology (RAM).
Recording Packaging Flows
Document packaging placed on the market per country. Include data on reusable packaging and material composition.
Using Approved Data Collection Tools
Utilise government-approved platforms for data submission.
Maintain consistency with agreed positions and technical interpretations for compliance:
- Ensuring Accuracy and Consistency
- Regularly update records to align with collection consistency requirements.
- Conduct internal audits to validate reported figures.
Submitting Data Within Deadlines
Follow country-specific reporting deadlines to avoid penalties. Use the ‘report packaging data’ account to manage submissions.
Here are some of the key compliance elements your business will need to understand to help meet EPR packaging:
- Producer responsibility regulations: Define duties for managing packaging waste.
- Environmental regulator fees: Businesses must pay annual fees to regulatory authorities.
- Nation-specific data reporting: Required to track where packaging is disposed of.
- Packaging recyclability assessments: Ensure materials align with national recycling infrastructure.
The table below illustrates how requirements and actions differ between small and large organisations:
| Compliance area | Large organisation (>£2m turnover & 50+ tonnes of packaging) | Small Organisations (< £2M turnover & <50 tonnes) |
| Data reporting | Bi-annual, detailed packaging reports | Annual data submission |
| Financial fees | Covers full recycling & waste management costs | Pays an annual regulatory fee |
| Recycling targets | PRNs & PERNs to meet recycling goals | Limited financial contributions |
| Nation-specific data | Required in many countries like the UK | Often simplified data submission |
EPR fees are financial contributions that packaging producers must pay to fund waste management and recycling systems. These fees are structured based on:
- Material type and recyclability
- Weight and volume of packaging placed on the market
- Country-specific regulations
- Waste management fee structure
Businesses can limit EPR fees by adopting reusable packaging and optimising design for recyclability.
Each country sets specific EPR reporting deadlines and data submission requirements. Businesses must comply with detailed data reporting obligations, which typically include:
- Total packaging placed on the market – Weight and type of materials used.
- Recyclability and recovery data – Information on how packaging materials are processed after disposal.
- Geographic data – Reports must outline where packaging is sold and disposed of to ensure compliance with national EPR frameworks.
- Financial contributions – Data related to payments made towards national waste management and recycling schemes.
- Supplier and supply chain information – Transparency on sourcing and packaging materials to support compliance efforts.
Each country sets specific EPR reporting deadlines. For example:
- UK: Annual packaging data submissions are due by April 1st, with quarterly updates required for high-volume producers.
- EU: Member states typically require annual reports by March 31st.
- Other markets: Reporting deadlines align with fiscal years, varying by national regulations.
EPR regulations drive sustainable packaging practices, benefiting both businesses and the environment by:
Business benefits:
- Cost savings – Reducing non-recyclable packaging can lower waste management fees.
- Brand reputation – Aligning with sustainability goals enhances public perception.
- Regulatory compliance – Meeting EPR requirements avoids penalties and ensures smooth operations in multiple markets.
- Innovation and efficiency – Encourages eco-friendly packaging design and material innovation.
Environmental benefits:
- Enhanced recycling infrastructure – Supports national waste management systems, improving material recovery rates.
- Reduced waste pollution – Encourages packaging that is recyclable or reusable, minimizing landfill dependency.
- Lower carbon footprint – Optimises circularity of packaging by reducing resource extraction and energy use.
- Improved consumer awareness – Mandatory binary labelling and the Recycle Now Mark guide consumers on correct disposal methods.
By participating in EPR, businesses contribute to a sustainable packaging ecosystem while strengthening compliance and brand sustainability efforts.
Different organisational structures, like parent companies and subsidiaries, have varying responsibilities when it comes to Extended Producer Responsibility (EPR) compliance. Businesses operating under a group structure must understand their reporting obligations to ensure full compliance with producer responsibility regulations.
- Parent companies & group reporting: In some jurisdictions, a parent company may be required to report on behalf of its subsidiaries to streamline compliance processes. However, in other cases, each entity must report independently. Understanding the agreed positions guidance in each country is crucial.
- Subsidiaries: Depending on the nation’s data submission requirements, subsidiaries may need to register separately for compliance schemes or align their reporting with the parent company.
- Account creation & registration: Businesses must ensure the correct setup of EPR compliance accounts, whether reporting as a single entity or as part of a corporate group.
Reconomy simplifies compliance for businesses with complex organisational structures by providing:
- Nation data alignment – Ensuring that all subsidiaries and parent companies meet national reporting obligations.
- Centralised compliance and group reporting – Through our Comply Loop brands, we provide group reporting solutions that reduce administrative burdens while ensuring full regulatory adherence.
- Agreed positions guidance – Our experts help businesses determine the most efficient compliance structure based on the latest producer responsibility regulations.
- Digital compliance solutions – Our platforms enable businesses to manage multiple accounts under a single reporting framework, ensuring accuracy and efficiency.
By partnering with Reconomy, businesses with complex organisational structures can streamline their EPR obligations, reduce costs, and ensure compliance across multiple jurisdictions.
How we help meet EPR packaging requirements
At Reconomy, we provide end-to-end solutions to help businesses navigate and comply with EPR packaging regulations. Our expertise in circular economy strategies ensures compliance while driving sustainability and operational efficiencies.
How we help businesses meet EPR compliance:
- Data & reporting solutions – We provide industry-leading data reporting tools that streamline compliance with packaging waste regulations across multiple jurisdictions.
- Global EPR compliance management – Our Comply Loop brands offer multinational compliance services, ensuring businesses meet EPR obligations worldwide.
- Technology-driven compliance tracking – Reconomy’s digital platforms enable real-time tracking, reporting, and auditing of packaging waste data, simplifying regulatory adherence.
- Financial management & cost optimisation – We help businesses manage financial contributions to EPR schemes efficiently, reducing unnecessary costs while ensuring full compliance.
- Customised advisory & consultancy services – Our expert consultants provide tailored strategies to optimise packaging design, reduce waste, and meet recyclability targets.
Reconomy’s services allow businesses to integrate EPR compliance seamlessly into their operations while benefiting from increased efficiency, cost savings, and enhanced sustainability credentials.
