UK Packaging EPR (pEPR) for Overseas and Marketplace Sellers in 2026

In short: Not directly. UK packaging EPR only makes businesses established in the UK into producers. When a non-UK seller sells on Amazon or another online marketplace, the marketplace operator is treated as supplying that packaging and reports it. A non-UK seller with a UK company, branch or importer may still have its own obligations.

Updated October 2026. This guide explains UK extended producer responsibility for packaging (pEPR) for overseas brands and marketplace sellers. It reflects the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 as of October 2026. It also draws on GOV.UK guidance from Defra, the environmental regulators and PackUK.

Does UK pEPR apply to non-UK sellers on Amazon?

Usually not to the seller itself. For sales by a non-UK seller through an online marketplace, the Regulations treat the marketplace operator as the supplier of the packaging.

• Producers must be UK-established: under regulation 15(1), a person is only a producer if it "is established in the United Kingdom". Regulation 4(1) covers, for example, habitual residence, a registered or head office, or a principal place of business in the UK.
• Marketplace treated as supplier: regulation 10(5) covers sales on an online marketplace by a person not established in the UK. In that case, "the online marketplace operator is to be treated as supplying that packaging".
• Marketplace is the producer: under regulation 20(2)(a), the operator is a producer for certain packaging. This covers items "supplied on the online marketplace by a non-UK supplier" and received in the UK.
• GOV.UK guidance: marketplace owners "should report any filled or unfilled packaging supplied by non-UK businesses through the marketplace".

This does not remove every duty from an overseas group. If you have a UK subsidiary, a UK importer or a UK packer, that business may be a producer in its own right. See our guide to extended producer responsibility for the general producer concept.

Who is an obligated producer under UK packaging EPR?

A UK-established business is obligated if it carries out a packaging activity and meets both a turnover and a tonnage test. GOV.UK says to check if you have turnover of £1 million or more and handle over 25 tonnes of packaging a year.

The Regulations set two producer sizes.

• Large producer (regulation 24(1)): turnover of more than £2 million and more than 50 tonnes of packaging supplied in the reference year.
• Small producer (regulation 24(2)): turnover of more than £1 million and more than 25 tonnes of packaging supplied, without meeting both large-producer tests.
• Below the small-producer tests: a business that does not meet both small-producer tests has no pEPR producer obligations.

The tonnage test uses packaging data from an earlier year. For example, GOV.UK says 2025 obligations used turnover to 7 April 2025 and 2024 packaging weight.

Which packaging activities and roles count?

GOV.UK lists six packaging activities. Each one can make a UK business responsible for specific packaging.

• Brand owner: supplying packaged goods to the UK market under your own brand.
• Packer or filler: placing goods into packaging, including unbranded packaging and, in some cases, packaging branded by a non-UK organisation.
• Importer: importing products in packaging. If the person importing is not UK-established, regulation 18(1)(a) makes the importer "the first person established in the United Kingdom who takes ownership of the packaging".
• Online marketplace owner: running a website or app that "allows non-UK businesses to sell their goods into the UK".
• Service provider: hiring or loaning out reusable packaging, reported the first time it is supplied.
• Distributor: supplying empty packaging, reported as "supplied as empty".

The Regulations also define a seller. Under regulation 22(1), a seller is a person who "supplies filled packaging to a final user of that packaging". A website that only sells goods from UK organisations is not an online marketplace for pEPR, although other activities may still apply.

When is an overseas brand still caught?

An overseas brand is caught when part of its UK supply chain is UK-established. The obligation then sits with that UK business, not with the overseas parent.

• UK subsidiary or branch: a UK company that imports or sells your goods is assessed against the thresholds in its own right.
• UK importer or distributor: the first UK-established business to take ownership of imported packaging is the importer.
• UK packer for an overseas brand: GOV.UK says obligations may also arise when a UK third party packs or fills goods for a non-UK company.
• Your UK entity's own web shop: a site selling only your own goods is not an online marketplace. The marketplace rule does not move that packaging away from your UK entity.

Mapping your UK entities and import flows comes first. Our article on import VAT in the UK and EU explains who acts as importer for tax purposes. Note that pEPR uses its own importer definition.

How do registration and the Report packaging data service work?

Obligated producers register with their environmental regulator through the Report packaging data service, or join a compliance scheme that registers them. The four regulators are the Environment Agency, the Scottish Environment Protection Agency (SEPA), Natural Resources Wales (NRW) and the Northern Ireland Environment Agency (NIEA).

• How to register: create an account on the Report packaging data service and upload organisation details as a CSV file. Then submit them to your regulator and pay the fee.
• Registration fee, large producer: £2,842 a year when registering directly.
• Registration fee, small producer: £1,303 a year when registering directly.
• Online marketplace owners: an additional £2,885.
• Compliance scheme members: £1,803 for large and £696 for small producers, plus the scheme's own fees.
• Late registration: an additional £386.
• 2026 registration deadlines: October 2025 for large producers and April 2026 for small producers.

If you stop being a producer, you must tell the regulator within 28 days. Regulators do not review an application until packaging data, registration data and the fee are all submitted.

What are the data reporting deadlines?

Large producers report every six months and small producers report once a year. Online marketplace owners also report nation data and their data collection methodology.

• Large producers, January to June: report by 1 October of the same year.
• Large producers, July to December: report by 1 April of the following year.
• Small producers, full calendar year: report by 1 April of the following year.
• Nation of sale data: due by 1 April of the following year for large and small producers. Marketplace owners must submit nation data for packaging sold by non-UK organisations.
• Marketplace methodology: a description of how data was collected, sent to the regulator by 1 April after the reporting year.
• Plastic and paper bags in England: the first mandatory report covers 2026 data and is due by 1 April 2027.

GOV.UK says you may need to pay a late fee if you miss a reporting deadline. Accurate SKU-level packaging data makes these returns much easier. See operationalising producer responsibility.

What fees do large producers pay in 2026?

Large producers pay waste disposal fees to PackUK, the scheme administrator, for household and commonly binned packaging. Small producers register and report but do not pay these fees or meet recycling obligations.

• Who pays: GOV.UK says large organisations pay waste disposal fees. A compliance scheme cannot pay them for you.
• Year 1 (2025 to 2026): fees for packaging placed on the market in 2024 were invoiced from October 2025.
• Year 1 base fees per tonne: aluminium £266, fibre-based composite £461, glass £192, paper and card £196, plastic £423, steel £259, wood £280, other £259.
• Year 2 (2026 to 2027): PackUK expects to calculate confirmed disposal fees in November 2026. It intends to issue the notice of liability at the end of November 2026.
• Recycling obligations: large producers may also need packaging recovery notes (PRNs or PERNs) to meet recycling obligations.

Year 2 illustrative fees per tonne (green / amber / red) were published in December 2025. They are not final, and PackUK warned they could change significantly:

• Aluminium: £245 / £270 / £325.
• Fibre-based composite: £475 / £525 / £630.
• Glass: £185 / £205 / £245.
• Paper and board: £190 / £210 / £250.
• Plastic: £415 / £455 / £545.
• Steel: £260 / £290 / £345.
• Wood: £410 / £450 / £540.
• Other: £205 / £225 / £270.

How do the recyclability assessment and modulated fees work?

From year 2, waste disposal fees vary with how recyclable packaging is. Producers self-assess packaging as red, amber or green using the Recyclability Assessment Methodology (RAM), and regulators check the ratings.

• First modulated year: 2026 to 2027 fees, calculated from packaging supplied in 2025.
• Amber: pays the base fee with no change.
• Red: pays 1.2 times the amber fee in 2026 to 2027, 1.6 times in 2027 to 2028 and 2 times in 2028 to 2029.
• Green: receives a discount funded by red fees, provisionally around 9% for year 2.
• RAM data: large producers' first batch of recyclability data, for January to June 2025, was due by 1 October 2025.
• Next methodology: PackUK planned to publish RAM 2027 by 1 July 2026.

For packaging design choices that lower fees, see packaging waste regulations and e-commerce.

What should overseas and marketplace sellers do now?

Confirm where your packaging obligation sits, then make sure the right UK business registers and reports. Most overseas sellers follow the same steps.

1. Check establishment: confirm whether any group entity is established in the UK.
2. Map sales channels: separate marketplace sales, own-website sales and B2B sales through UK distributors.
3. Identify the producer: for marketplace sales by a non-UK entity, the marketplace operator reports the packaging. For UK entities, apply the activity and threshold tests.
4. Share packaging data: marketplaces must report packaging weights, so keep material and weight data per SKU ready.
5. Register if obligated: register through the Report packaging data service or a compliance scheme, and diarise the 1 April and 1 October deadlines.
6. Review recyclability: assess packaging against the RAM before red multipliers rise in 2027 to 2028.

UK selling also involves VAT. See sell on Amazon UK in 7 steps, our UK VAT guide and the UK vs the EU for Amazon sellers. If you also sell into the EU, Taxually's EcoTax covers EPR in Germany, France and Spain.

Sources

• legislation.gov.uk: The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332)
• GOV.UK: Extended producer responsibility for packaging: who is affected and what to do
• GOV.UK: Packaging data: what to collect for extended producer responsibility
• GOV.UK: Register with the environmental regulator: extended producer responsibility for packaging
• GOV.UK: Extended producer responsibility for packaging: recycling obligations and waste disposal fees
• GOV.UK: Extended producer responsibility for packaging: 2025 base fees
• GOV.UK: Year 2 illustrative waste disposal fees
• GOV.UK: PackUK operational plan 2026 to 2027
• GOV.UK: PackUK producer disposal fees modulation statement