What are the UK EPR registration and payment obligations, timelines, and revenue thresholds for drinks businesses?
UK EPR compliance hinges on revenue thresholds and financial year timing. Here's what the community understands:
**Revenue thresholds and liability:** - Businesses with **£1m+ UK revenue** are classified as 'small' producers; those at **£2m+ become 'big'** producers - **Only UK revenue counts** — export revenue is excluded from the threshold calculation - Liability to pay begins in the financial year *following* the year you cross the revenue boundary (not immediately upon crossing) - There is also a **tonnage exemption** (specific threshold not recalled by discussants)
**Registration and submission timeline:** - **31st May 2024** was the registration and data submission deadline to the Environment Agency - Payment obligations vary by producer size; businesses under £2m revenue may not be liable to pay immediately (unless they fall into PRN-paying categories)
**Caveats:** - Members noted there is "a lot of confusion" and limited discussion in the industry about exact requirements. The specifics of which financial year triggers liability can vary depending on your reporting period, so verification with your own accountant or the Environment Agency is advised. - Miles Beale's article in The Spirits Business (January 2025) was flagged as a useful, recent reference point on EPR concerns.
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