What are the EPR thresholds and exemptions for packaging in the UK?

The UK's Extended Producer Responsibility (EPR) scheme has a **dual threshold exemption**: you must be over **£1m in annual turnover AND produce over 25 tonnes of packaging waste** to be in scope. If you fall below either threshold, you're exempt.

- **Threshold detail**: 25 tonnes of packaging waste equates to approximately 41,000 glass bottles at 600g each. This applies at the **manufacturer level**, not the distributor or wholesaler level—so many smaller brands remain exempt even if their products are distributed by larger wholesalers or traded distributors who themselves exceed the threshold. - **Implementation timeline**: A Designated Managing Organisation (DMO) is being appointed in April, with fees becoming volume-based and applying from **27 October** onwards. At that point, all producers, wholesalers, and other supply-chain participants above the exemption threshold must be registered. - **Official guidance**: The government's full guidance is available at gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do

**Note**: The exemption structure means the threshold is clearer for manufacturers than for other actors in the supply chain (wholesalers, distributors), and members confirmed the manufacturer-level application of the thresholds.