Small Producer Thresholds
Many UK SMEs are unsure whether they fall under the new Extended Producer Responsibility (EPR) rules. The distinction between small and large producers affects everything - data requirements, reporting frequency, fees, and the risk of penalties.
This guide explains the thresholds clearly and uses real examples so you can confirm your position quickly and avoid costly misreporting in 2025–26.
Incorrect classification now can affect your 2025 reporting cycle and may increase your 2026 modulated fees or lead to Environment Agency penalties.
What Is a Small Producer Under EPR?
Under the UK’s packaging EPR regulations, an organisation is considered a small producer if it meets both of the following:
✔ Annual turnover of £1 million or more, AND
✔ Handles or supplies between 25 and 50 tonnes of packaging in a calendar year
If you fall below £1m turnover, you are out of scope.
If you handle fewer than 25 tonnes → out of scope.
If you handle more than 50 tonnes → large producer.
Important:
Being “out of scope” does not mean EPR never applies. You must still confirm your status each year and monitor packaging growth - businesses can easily cross thresholds as sales increase.
What Does This Mean in Practice?
Small producers must:
Register annually
Submit one annual packaging data report
Pay the small administration fee
Keep evidence for 7 years
Small producers do not pay:
2025 household packaging disposal fees
2026 RAM-based modulated fees
Scheme administrator fees (PackUK charges)
However:
If your business crosses the 50-tonne threshold, even mid-year, you must transition to large producer obligations. This is why accurate supplier data is essential.
Examples to Make Classification Clear
Example 1 - In scope as a small producer
A skincare brand with:
£2.1 million turnover
32 tonnes of packaging handled
→ Small producer
→ Annual report only
→ No 2026 modulated fees
Small producers should still maintain internal RAM documentation even though they don’t submit RAM scores because:
Suppliers are already using RAM in some sectors
A producer may accidentally cross the 50-tonne threshold mid-year
EA audits may track year-to-year changes
Example 2 - Out of scope
A coffee business with:
£700k turnover
28 tonnes packaging handled
→ Out of scope
→ Must still monitor growth but no reporting duty
Businesses out of scope may still need to register in future years if packaging volumes grow or if their supply chain changes (e.g., importing, platforms).
Example 3 - Large producer
A drinks company with:
£3.2m turnover
75 tonnes packaging handled
→ Large producer
→ Twice-yearly reporting
→ Fees payable
→ RAM-based 2026 fees apply
Common Misunderstandings SMEs Have About Thresholds
“We import small quantities so we’re not in scope.”
If you exceed 25 tonnes and meet the turnover threshold, you may still be classified as a small producer (with reporting obligations).
“We don’t manufacture packaging; we’re not responsible.”
Under EPR, “producer responsibility” often sits with the brand owner or importer placing packaged goods on the UK market, even if packaging is manufactured elsewhere.
“We’re a small business, so we must be a small producer.”
Business size does not automatically determine producer status - packaging tonnage and turnover thresholds apply independently.
“Amazon fulfils our orders; they handle compliance.”
Using a fulfilment provider (e.g. Amazon FBA) does not automatically transfer EPR responsibility. Liability remains with the producer unless explicitly reassigned under a compliant contractual arrangement.
“Our packaging is eco-friendly so our fees will be lower.”
RAM classifications are based on DEFRA-defined recyclability assessments and evidence - not general sustainability or marketing claims.
What Small Producers Need to Report
You must submit:
Total packaging supplied or imported
Material breakdowns (plastic, paper, wood, metal, glass, etc.)
Country of supply
Household vs non-household packaging volumes
You do not need RAM ratings - these apply to large producers for 2026 modulation. However, you should still track material-level weights carefully - incorrect data can push you above 50 tonnes, changing your status entirely.
How Thresholds Affect 2025 - 2026 Reporting Deadlines
Small Producers:
Register by 1 April each year, if in scope for the year.
Submit one annual dataset
Next submission: 1 April 2026 for 2025 data
Large Producers:
Submit twice yearly (H1 + H2)
Pay fees
Must prepare for RAM-based modulated fees from 2026
Why Getting This Wrong Can Lead to Penalties
Misclassification is one of the top reasons SMEs are fined by the Environment Agency.
Risks include:
Incorrect fee payments
Under-declaration of packaging
Being placed under audit
Penalties can escalate if misreporting is deemed deliberate or repeated.
Having to re-submit corrected data
Correct reporting is cheaper than incorrect reporting.
Recommended Next Step for SMEs
If you're unsure whether EPR applies to your business or which reporting cycle you fall under, you can book a short Free Readiness Review.
This 15-minute scoping call helps you:
Understand whether EPR is likely to apply to your business based on the information you provide
Clarify which reporting cycle (annual or twice-yearly) may be relevant
Identify what information you’ll need from suppliers
Understand the next steps toward compliance
