Quick test: are you in scope at all?
Government guidance says you need to collect and report packaging data for a given year if all of these apply:
- You are an individual business, subsidiary, or group — and you are not a charity for the purposes of producer obligations.
- Your annual turnover is £1 million or more.
- You were responsible for supplying or importing more than 25 tonnes of packaging in the previous calendar year.
- You carry out at least one packaging activity (see Section 3).
If you fail any of those tests, you may be out of scope for that year — but re-check each year as turnover and packaging amounts change.
GOV.UK explains that charities are exempt from obligations and fees as packaging producers, but different rules can still apply in other roles — for example, if acting as a reprocessor or exporter.
Small producer vs large producer
Government guidance defines a small producer as an organisation that either:
- Has annual turnover of more than £1 million and up to £2 million and supplies more than 25 tonnes of packaging in the UK, or
- Has annual turnover of more than £1 million and supplies more than 25 tonnes and no more than 50 tonnes of packaging in the UK.
If your turnover is £2 million or more and you supply more than 50 tonnes, you are a large producer — reporting is bi-annual, and waste disposal fees and PRN obligations apply.
"Small" is not about how many people you employ. Classification is based purely on financial turnover and packaging tonnage.
What counts as a packaging activity?
Government guidance lists six activities that can trigger an obligation. You only need to carry out one of these to be in scope:
- Supplying packaged goods to the UK market under your own brand
- Packing or filling packaging
- Importing products in packaging
- Supplying empty packaging
- Hiring or loaning out reusable packaging
- Operating an online marketplace where non-UK sellers sell into the UK
What small producers must do — the real-world steps
The reporting rules you must not get wrong
Government guidance says small producers must:
- Record all drinks containers as household drinks containers
- Report plastic simply as "plastic" — do not split into rigid and flexible
- Only use the codes SP (small organisation packaging — all) and HDC (household drinks containers)
| Code | What it covers |
|---|---|
| SP | All packaging you are responsible for — all classes and all activities |
| HDC | All drinks containers — must be recorded as HDC, not SP |
GOV.UK file specifications state that packaging material weight must be entered using digits only, in whole numbers (kilograms). If your file fails portal validation it will not upload — you must correct and re-upload.
The portal will not accept .xls or .xlsx files. Your file must be a true CSV conforming exactly to the government's file specification. A formatting error means rejection with no mechanism to fix it after the deadline.
Plastic and paper bags supplied in England
Government guidance states the first mandatory report for plastic and paper bags supplied in England is for 2026 data, due by 1 April 2027.
It also points you to the Environment Agency's Regulatory Position Statement (RPS 330) about collecting and submitting 2025 plastic and paper bag data. If bags are relevant to your business, read and follow that statement before your next submission.
Fees — and the official discrepancy you must not ignore
Official GOV.UK pages currently show different fee schedules for small producers:
| GOV.UK page | Direct registration | Via compliance scheme | Late fee |
|---|---|---|---|
| "Register and pay the fee" guidance | £1,303 | £696 | £386 |
| "Small producer" guidance | £1,216 | £631 | — |
Because official GOV.UK pages currently list different fee amounts, check the fee shown in the Report Packaging Data service at the time you register and cross-check the 'register and pay the fee' guidance. Keep a dated screenshot or record of what you were shown.
What small producers do not have to do
Government guidance is explicit. As a small producer you do not have to:
- Pay waste disposal fees
- Buy packaging waste recycling notes (PRNs) — the evidence large producers use to meet recycling obligations
If a service provider quotes you for a large-producer compliance bundle and you are a confirmed small producer, question it. These are materially different obligations.
If you do nothing — the consequences
Government guidance warns that if you do not submit mandatory information and pay by the deadline, you may have to pay late fees and may be subject to enforcement action.
In England, civil sanctions are available under this regime. A fixed monetary penalty of £1,000 (increasing by 50% if not paid within 56 days) applies to certain contraventions such as record-keeping and evidence duties. Failures to register or report data — the most common breaches — are subject to variable monetary penalties and compliance notices instead, calculated case-by-case with no fixed upper limit.
The fixed £1,000 penalty applies only to record-keeping failures. For registration and reporting failures, variable monetary penalties apply with no fixed upper limit.
Official sources used
- GOV.UK — EPR for packaging: what you must do as a 'small producer'
- GOV.UK — Extended producer responsibility for packaging: register and pay the fee
- GOV.UK — Packaging data: what to collect for extended producer responsibility
- GOV.UK — Environment Agency RPS 330: EPR for packaging producer data requirements for 2024 and 2025
- GOV.UK — Packaging data: check reporting periods and submission deadlines
- GOV.UK — File specification for packaging data from 2025
- GOV.UK — Environment Agency enforcement and sanctions policy: Annex 4
- GOV.UK — Extended producer responsibility for packaging: who is affected and what to do
Relicare is an independent data preparation service and is not a registered compliance scheme. Always verify current fees and deadlines at the official GOV.UK Report Packaging Data service.