Large Producer Obligations Explained
(UK EPR 2025–2026)
Understanding your duties, data requirements, and reporting expectations under the current EPR regulations.
Businesses classified as Large Producers under UK EPR must meet enhanced reporting, evidence, and fee obligations. This guide explains the criteria, data requirements, and steps needed to stay compliant with 2025–2026 rules.
What Is a Large Producer Under UK EPR?
Under the Extended Producer Responsibility (EPR) regulations, a business is classed as a Large Producer if it meets both of the following criteria in the previous calendar year:
✔ Annual turnover of £2 million or more, and
✔ Handles 50 tonnes or more of packaging
“Handles” refers to any activity that places packaging on the UK market, including:
Manufacturing
Importing
Selling packaged goods
Supplying goods via online marketplaces
Hiring or leasing reusable packaging
If both thresholds are met, the business must follow the full set of large producer obligations.
Not a Large Producer?
Businesses below one or both thresholds may instead fall under the Small Producer category.
Why the Large Producer Category Matters
Becoming a Large Producer brings significantly higher responsibilities than small producers, including:
More detailed data collection
Semi-annual reporting
Use of DEFRA-approved data formats
Modulated fees from 2026
Additional record-keeping duties
For many SMEs on the threshold, this classification is the difference between a straightforward annual declaration and a complex reporting cycle involving suppliers, materials, formats, and recyclability.
Key Obligations for Large Producers (2025–2026)
Large Producers must meet all of the following requirements.
3.1 Register by the Required Deadline
Large Producers must register on the regulatory service (or through their compliance scheme) by the dates set out in GOV.UK guidance.
Registration includes:
Company details
Packaging activities
Nation data (see next section)
Confirmation of producer category
Failure to register can result in enforcement action or penalties.
3.2 Submit Nation Data
Large Producers must provide nation data, which shows where in the UK packaging is:
Supplied
Discarded
Imported
Exported
This ensures accurate allocation of waste management costs across England, Scotland, Wales, and Northern Ireland.
3.3 Report Packaging Data Twice Per Year
Large Producers must submit packaging data on a semi-annual basis:
January - June period
July - December period
Reports must include:
Packaging handled by material type
Packaging type and function categories
Tonnage data per activity (e.g., imported, supplied, filled, own-brand)
Supplier-sourced information (where applicable)
Reports must include packaging handled by material type, such as plastic, paper/card, aluminium, glass, wood, and composite materials.
Correct formatting and accurate record structures are essential to avoid errors.
3.4 Maintain Accurate Evidence and Records (Seven-Year Requirement)
Businesses must keep detailed records for up to seven years.
Examples include:
Supplier data and declarations
Material specifications
Packaging formats
Evidence supporting all reported tonnage
Estimates (where used) with documented methodology
Contracts, invoices, and internal systems records
This is one of the largest compliance burdens and a major area where SMEs struggle without structured processes.
3.5 Pay Modulated Fees from 2026 (Where Applicable)
Modulated fees are expected to apply from 2026, subject to final confirmation of fee structures by government.
Large Producers must therefore:
Monitor packaging formats and recyclability
Understand which materials attract higher fees
Prepare for financial planning and potential cost increases
Ensure supplier information is accurate and up to date
This is a core area where EPR Horizon can provide forecasting and readiness support.
3.6 Work With Suppliers to Ensure Data Accuracy
While producers remain legally responsible for the submission, they may request and review supplier information to support accurate reporting.
Request data from suppliers
Verify formats, materials, and weights
Clarify data inconsistencies before reporting
Approval must be given by the producer for any supplier engagement activity.
The obligation to submit accurate data always remains with the producer.
3.7 Submit Required Returns in Approved Formats
Data must be submitted in the correct structure using DEFRA’s required data fields and submission format.
Large Producers benefit from using structured templates and validation processes to reduce risk.
Common Challenges for Large Producers
Many businesses crossing the threshold face similar challenges:
• Data held across multiple suppliers
Packaging formats, weights, and material splits are often inconsistent or incomplete.
• Limited visibility over imported packaging
Supplier variations cause discrepancies in reported tonnage.
• Manual spreadsheets leading to errors
Without structure, errors compound over a six-month period.
• Difficulty forecasting future EPR costs
2026 modulated fees require early planning to avoid cost shocks.
• Internal resource constraints
EPR reporting requires ongoing attention, not one-off work.
These challenges make large producers significantly more exposed to penalties, inaccurate reports, or unnecessary costs.
How EPR Horizon Helps Large Producers
EPR Horizon supports large producers through a structured, compliance-focused approach that includes:
✔ Data structuring and validation
Ensuring packaging data is captured correctly across suppliers and formats.
✔ DEFRA-aligned templates and submission files
Reducing errors and ensuring all required fields are complete.
✔ Semi-annual reporting support
Guided preparation for both reporting cycles.
✔ Modulated fee readiness (2026)
Understanding recyclability impacts and forecasting fee exposure.
✔ Supplier engagement support (with producer approval)
Standardised requests and formats to secure reliable information.
✔ Long-term record-keeping frameworks
Ensuring a smooth, compliant seven-year retention process.
The goal is clarity, accuracy, and full readiness before the reporting deadlines approach.
Unsure Whether You’re a Large or Small Producer?
