The two tests
The turnover test is your annual turnover. The tonnage test is the weight of packaging you supplied to the UK market in the relevant year - all of it, not just the packaging you manufactured, and not just the packaging that ends up in a household bin.
The tests are cumulative. A business supplying 400 tonnes of packaging on a £900,000 turnover is not obligated. A business with £40m turnover supplying 20 tonnes is not obligated either. Both numbers have to be over the line.
| Packaging supplied | Turnover £1m or less | Turnover over £1m to £2m | Turnover over £2m |
|---|---|---|---|
| Under 25 tonnes | No obligation | No obligation | No obligation |
| 25 to 50 tonnes | No obligation | Small producer | Large producer |
| Over 50 tonnes | No obligation | Small producer | Large producer |
Check your position
Enter your annual turnover and the tonnage of packaging you supplied to the UK market.
Both figures are needed - the tests are cumulative, so one number on its own decides nothing.
What counts towards your tonnage
The tonnage test catches more than most businesses expect on first reading, because it is about packaging you supplied rather than packaging you made. The activities that bring packaging into scope include supplying it under your own brand, importing packaged goods, selling packaging to businesses that are not themselves obligated, hiring or lending out reusable packaging, and supplying packaging for online sales.
It also includes all three levels of packaging, not just the box the customer sees. Primary packaging around the product, secondary packaging grouping it, and transit packaging protecting it in the supply chain all count towards the tonnage.
The tonnage most often missed:
- Transit packaging - pallets, stretch wrap, corner boards, void fill
- Packaging on imported goods, where the tonnage arrived already assembled and nobody weighed it
- Shipping and fulfilment materials for online orders
- Packaging supplied to unobligated business customers
- Reusable packaging placed on the market for the first time
This is the point at which a business that assumed it was under 25 tonnes often discovers it is not. Getting the number right means weighing components, which means holding component-level packaging data - and a business close to a threshold has a strong reason to know its tonnage accurately rather than approximately.
Small producer or large producer
| Duty | Small producer | Large producer |
|---|---|---|
| Register with the regulator | Yes | Yes |
| Report packaging data | Once a year | Twice a year |
| Level of detail | Aggregate by material | Broken down by material, level, use and activity |
| RAM recyclability assessment | No | Yes, on household packaging |
| Disposal fees | No | Yes, per tonne and modulated by rating |
| Nation-level data | No | Yes |
The gap between the two is wide enough that a growing business should know in advance which year it crosses. A small producer keeps records and files once. A large producer runs a recyclability assessment across its household portfolio, reports at component granularity twice a year, and pays a bill that scales with tonnage and rating.
Common questions
Do I need to register if I am under the thresholds?
No. If you are below either threshold you have no registration or reporting duty under packaging EPR. Keep the working that shows you are below it, because the position is tested each year and a growing business can cross without noticing.
Does transit packaging count towards the tonnage test?
Yes. Primary, secondary and transit packaging all count towards the tonnage you supplied. Pallets, stretch wrap and void fill are routinely left out of a first estimate, and they are often what carries a business over 50 tonnes.
What if my turnover is over £2m but my tonnage is under 25 tonnes?
You have no obligation. Both tests have to be met. Under 25 tonnes there is no obligation at any turnover.
Which turnover figure applies?
Your annual turnover for the relevant assessment year. For a group structure, the obligation is assessed against the organisation that meets the definition of the producer for the packaging in question, which is worth confirming with your compliance scheme if your group supplies through multiple entities.
Is packaging on imported goods my obligation?
If you import packaged goods into the UK, the packaging around them counts towards your tonnage. That includes packaging you had no part in specifying, which is why importers usually have to ask suppliers for component weights they have never previously held.
What happens if I should have registered and did not?
Packaging EPR is enforced by the environmental regulators, who can take enforcement action for failure to register or report. If you find you have crossed a threshold in a past year, the sensible order is to establish the correct tonnage first, then approach the regulator or your compliance scheme with a number you can stand behind.
How Merchant Packaging helps
Read next
Sources
- GOV.UK: check if you need to report packaging data
- GOV.UK: extended producer responsibility for packaging, what you need to do
Packaging regulation moves. This page states the date it was last reviewed against its sources, and where a figure is illustrative rather than confirmed the text says so.