Packaging regulations FAQs

You could be classed as Brand owner, packer/filler, importer, distributor, online marketplace or service provider depending on the activities you perform on the packaging.

To identify your producer type for 2025 obligation year (reporting data for period of January to December 2024), you will need to look at your turnover on accounts submitted to Companies House prior to 7th April 2024. Your tonnage threshold is identified based on packaging handled in the period of January to December 2023.

Your packaging can be classed as household, non-household, street bin, drinks containers, re-useable or self-managed waste.

You must record your packaging weights in kgs by material type. Material types include Paper, Glass, Aluminium, Steel, Plastic, Wood, Fibre-based Composite or Other.

Your packaging can be classed as Primary, Secondary, Shipment or Tertiary. Primary (or POS) packaging is packaging around a single sale unit which most likely will be removed by the end consumers. Secondary (or Outer) packaging is packaging grouping number of sales unit, such as outer box and tape around it. Tertiary (or Transit) packaging is packaging grouping number of sales or outer units; usually helping with transportation of goods such as pallets and pallet wrap. Shipment packaging is outer o transit packaging intended to be supplied to a household customer.

You need to report this data if you supply filled or empty packaging directly to customers in the UK, where they are the end user of the packaging, supply empty packaging to UK organisations that are either not legally obligated, or are classed as a small organisation, hire or loan out reusable packaging, own an online marketplace where organisations that are based outside the UK sell their empty packaging and packaged goods to UK users, import packaged goods into the UK for your own use and discard the packaging.

Organisation waste is type of self-managed waste (one of the waste types). Organisation waste data are only required for reporting purpose and include all packaging you have discarded and sent for recycling. You also need to identify where the waste was collected and transferred to - England, Scotland, Wales or Northern Ireland.

As a large producer you are required to report your data twice a year – by 1st April (for July to December period of previous year) and 1st October (for January to June of that year).

As a small producer you are required to report your data once a year – by 1st April (for January to December period of previous year).

Exported packaging is exempt from the regulations.

You could be subject to enforcement action including fines and penalties.

You might be obligated to comply for previous year if you met the thresholds for that years. The process of complying for previous years is called Enforcement Undertaking, which can be active or reactive.

You can comply directly or through Compliance Scheme. Most of the UK businesses prefer to comply through Compliance Scheme and they take majority of the burden with complying.

The Environment Agency might have contacted you because they believe you meet the threshold criteria of complying. You should provide the evidence if this is not the case or start complying as soon as possible.

The Environment Agency charges registration fees, as well as any late or resubmission fees.

If you handle household packaging, you will need to pay household fees directly to Scheme Administrator.

On top of that, you are required to purchase Packaging Recovery Notes (PRNs) to offset your obligation that also come with addition cost.

Yes, you can become a consultancy member only where we help you calculate your obligation only without submission or PRN procurement.

We can resubmit your data by the end of the obligation year. Please note, you will be subject to resubmission fees for each data set resubmitted.

For each obligation year you will receive certificate of compliance. This is issued the following February. For example, for obligation year 2024, you will receive your certificate of compliance in February 2025.

When you reach the 10 tonne threshold you are required to register with HMRC, within 30 days.

You must record your packaging weights in kgs.

Once you have registered, you will need to submit quarterly returns.

Exported packaging is exempt from the regulations, however it does count towards your 10 tonne de-minimis.

Late submissions are picking up higher fees depending on how late they are.

You might have been obligated to comply for previous years (since 2022) if you met the 10 tonne threshold. You can still submit your data late anytime.

You can only comply directly under Plastic Packaging Tax. However, we at Kite offer Plastic Packaging Tax consultancy where we help you calculate figures to be submitted to HMRC.

The HMRC might have contacted you because they believe you meet the criteria of complying. You should provide the evidence if this is not the case or start complying as soon as possible.

The rate is £217.85 per tonne, and it applies to all plastic packaging, containing less than 30% recycled plastic that is manufactured and imported into the UK on and after 1‌‌‌ ‌‌April 2024.