Small or large producer
Once an organisation is obligated, it is either a small producer or a large producer. The difference is not cosmetic: a large producer reports twice a year instead of once, pays a waste disposal fee, has to acquire PRNs or PERNs to meet recycling obligations and has to submit a certificate of compliance. A small producer registers, reports once a year and keeps records.
Two figures decide it, and both have to be read carefully.
The two tests
Worldwide annual turnover. Turnover is worldwide annual turnover, not UK turnover. This is stated in the source as 'your annual turnover worldwide'. Using a UK-only figure will misclassify producers. This is the single most common error in the whole scheme. A UK subsidiary of a large foreign group can look tiny on its own accounts and still be a large producer, because the test does not look at UK revenue.
Packaging tonnage. The weight of packaging supplied or imported in the previous calendar year. When adding up packaging supplied or imported for the threshold test, count each item of packaging once even if you carry out more than one packaging activity on it.
Turnover comes from accounts: If you publish or otherwise make available audited accounts each year, you must use those. If you are not required to submit audited accounts, use whatever accounts are available. The annual turnover figure must be taken from the last accounts that were available before 7 April 2026.
The page as retrieved on 5 September 2026 states the periods for reporting 2026 packaging data only. The 7 April date applies to 2026 reporting only. Check the date for any other year.
The matrix
ConfirmedEvery threshold in this table.
| Packaging weight | £1 million or less annual turnover | From £1 million to £2 million annual turnover | More than £2 million annual turnover |
|---|---|---|---|
| Less than 25 tonnes | No obligation | No obligation | No obligation |
| From 25 tonnes to 50 tonnes | No obligation | Small producer | Small producer |
| More than 50 tonnes | No obligation | Small producer | Large producer |
The thing to take from that table is that both conditions have to be met for large producer status. Worldwide turnover above £2 million, packaging from 25 to 50 tonnes. → Small producer, not Large producer. Both conditions must be met for large producer status. High turnover on its own does not make a producer large.
People get this wrong in the direction of caution. They see a turnover well above the top band, assume large producer status and take on the six-monthly reporting and the PRN obligation they do not have. The tonnage row is what governs at that point.
Source: Check if you must comply with EPR for packaging (Environment Agency / Defra, GOV.UK guidance). Retrieved 2026-09-05. Source last updated 2026-08-19.
Two places the guidance contradicts itself
The guidance states the obligation test twice: once as prose describing an obligated producer, and once as the table above. At two exact values the two statements do not agree. This is not ambiguity that careful reading resolves: the two passages give opposite answers.
The guidance contradicts itself at exactly 25 tonnes
The obligated producer test says you are obligated if you supplied or imported 'more than 25 tonnes'. On that wording, exactly 25 tonnes is not obligated.
The threshold table puts 'From 25 tonnes to 50 tonnes' in the small producer band. On that wording, exactly 25 tonnes is a small producer.
The calculator on this site follows the table. Confirm with your environmental regulator before relying on either reading. A tonne either side of the boundary removes the ambiguity.
The guidance contradicts itself at exactly £1 million turnover
The obligated producer test says turnover of '£1 million or more' is obligated. On that wording, exactly £1 million is obligated.
The threshold table puts '£1 million or less annual turnover' in the no obligation band. On that wording, exactly £1 million carries no obligation.
The calculator on this site follows the table. Confirm with your environmental regulator before relying on either reading.
In practice a producer sitting exactly on either value is rare, and a producer sitting near either value should be more worried about whether the underlying tonnage or turnover figure is right than about the boundary itself. But if you are genuinely on the line, the guidance will not settle it for you.
Groups and subsidiaries
A holding company must check whether its corporate group is obligated as a large or small producer, using the totals for all companies in the group that are established in the UK and supply or import any packaging.
You need, for the group as a whole:
- the total weight of filled or unfilled packaging supplied or imported into the UK
- the total annual turnover worldwide
Do not include the turnover of any companies in the group that do not supply or import packaging.
If the group totals meet the large producer criteria, every member of the group is a large producer; if small, every member is small. It does not matter whether members meet the criteria individually. That last point is the one worth sitting with. Group status is decided once, on combined totals, and then applied to every member. A subsidiary handling two tonnes of packaging a year can be a large producer because of what the rest of the group does.
The corollary is that you cannot work out group status by testing members individually. The calculator here takes one set of figures; for a group, combine the totals first and enter those.
Establishment in the UK
An organisation is 'established in the UK' if its registered office, head office or principal place of business is in the UK. This includes an organisation run out of domestic premises in the UK.
If the head office is outside the UK, the organisation is still established in the UK if it has any of the following:
- a branch in the UK
- a warehouse in the UK
- a PO box, returns address or any other postal address in the UK
A returns address is enough. An overseas business that has done nothing more than arrange a UK address for customer returns meets this test.
Charities
Charities that supply or import filled or unfilled packaging in the UK are exempt from EPR for packaging requirements.
This does not include subsidiaries of a charity that trade for profit. Those subsidiaries are not covered by the exemption. A charity with a trading arm should expect the trading arm to be assessed on its own terms.
The GOV.UK change log for this page records, at 10 February 2026, that 'charities are not exempt from reprocessor or exporter obligations'. The exemption above concerns producer obligations.