Most business owners I speak with think packaging EPR regulations don’t apply to them. They’re confident their company is too small, or they simply don’t “produce” packaging in the traditional sense.
Then I show them the numbers. 50,000 kg of packaging isn’t what they imagined. It’s not a warehouse full of materials. It’s the everyday cups, containers, and boxes going through their business.
If your business turns over more than £1 million annually, this matters to you. The threshold determining whether you’re caught by these regulations is lower than you think.
I was compelled to write this after hearing similar stories from an FPA article and building on my own expereinces with new client projects over the last year – they had just stumbled across this new EPR fee and had to pay.
The Hidden Scale of Packaging
Most businesses miss this: packaging is light. A single takeaway container weighs 30-40 grams. A paper coffee cup weighs 12-15 grams. When you’re dealing with items this light, the unit volumes required to hit regulatory thresholds are massive.
The Packaging EPR regulations set two key thresholds:
– Small producers: 25,000 kg (25 tonnes)
– Large producers: 50,000 kg (50 tonnes)
These sound like enormous quantities. They’re not.
What Does 25,000 kg Actually Look Like?
For a small producer operating at the 25,000 kg threshold, here’s what that mass translates to in real business operations:
| Business Type | Typical Packaging Mix | Annual Unit Volumes |
| Small Beverage Operation | 80% PET bottles (500ml), 20% secondary packaging | ~850,000 to 1 million bottles, plus ~10,000 corrugated cases |
| Local Coffee Shop Chain | 70% paper cups, 20% lids, 10% sleeves and trays | ~1.15 to 1.45 million cups, plus matching lids and ~100,000 trays |
| Independent Takeaway | 60% food containers, 25% cups, 15% other packaging | ~375,000 to 500,000 containers, ~350,000 cups, ~250,000 other packaging units |
| Small Pizza Delivery | 70% pizza boxes, 20% inserts/liners, 10% transit cases | ~80,000 to 95,000 pizza boxes, plus inserts and ~4,000 to 5,000 cases |
These aren’t theoretical scenarios. These are real volumes that typical small to mid-sized businesses handle every year without realising they’ve crossed into regulated territory.
What Does 50,000 kg Actually Look Like?
For businesses at the large producer threshold of 50,000 kg, the scale doubles, but the impact is even more significant:
| Business Type | Typical Packaging Mix | Annual Unit Volumes |
| Beverage-Led Operation | 80% PET bottles (500ml), 20% secondary packaging | ~1.7 to 2 million bottles, plus ~20,000 corrugated boxes |
| Takeaway-Focused Restaurant Chain | 60% food containers, 25% cups, 10% other packaging sets | ~750,000 to 1 million containers, ~700,000 cups, ~500,000 other packaging sets |
| Coffee Chain Supply | 70% paper cups, 20% lids, 10% sleeves and trays | ~2.3 to 2.9 million cups, plus matching lids and ~200,000 trays |
| Pizza or Hot Food Delivery | 70% pizza boxes, 20% inserts/liners, 10% transit cases | ~160,000 to 190,000 pizza boxes, plus inserts and ~8,000 to 10,000 cases |
| Mixed HoReCa Wholesaler | 35% containers, 25% bottles, 20% cups, 10% other packaging sets, 10% boxes | ~400,000 containers, ~500,000 bottles, ~800,000 cups, ~600,000 other packaging sets, ~8,000 boxes |
Why This Matters More Than You Think
Notice something? These aren’t multinational corporations. These are successful regional chains, busy takeaways, wholesalers serving the hospitality sector. Businesses that consider themselves “medium-sized” at best.
The disconnect between perception and reality creates three critical business risks:
1. Underestimation of scope Business owners think in terms of pallets delivered or monthly orders placed. They don’t mentally convert that into the millions of individual units they’re actually placing on the UK market. A single pallet of cups might contain 10,000 units weighing just 120-150 kg total.
2. Fee exposure based on mass Your EPR fees are calculated on total packaging mass. But the operational complexity, recyclability assessment methodology (RAM) burden, and compliance risk are driven by unit count and SKU diversity. You’re paying for tonnage but managing millions of individual items.
3. The design change leverage Here’s the opportunity most businesses miss: at these volumes, small changes in procurement and design create massive impact. Reducing the weight of a single cup by just 2 grams across 2 million units saves 4 tonnes of reported packaging. That’s around £2,000 in annual EPR fees, rising by 20% in 2026 depending on material and recyclability for just one product category. Apply this over 5 products and you are talking about £10,000 extra costs.
The Real Question You Should Be Asking
It’s not “Do these regulations apply to me?”
The question is: “How much am I already spending in EPR fees, and how much could I save through smarter packaging decisions?”
Most businesses I work with discover they’re not just over the threshold, but they’re significantly over it. Others see they’ve been paying EPR fees without understanding the underlying drivers, optimising their packaging strategy to reduce both environmental impact and compliance costs, or simple misinterpreting the law and shooting themselves financially in the foot under the new EPR Regulations.
What You Can Do Right Now
If you’re a business with turnover exceeding £1 million and you handle any of the following, you need to assess your position:
✓ Serve food or beverages in disposable packaging ✓ Retail products in branded packaging ✓ Distribute goods in transit packaging ✓ Wholesale to hospitality, retail, or catering businesses ✓ Operate franchises or multiple locations
The good news? Once you understand your packaging profile, there are proven strategies to:
– Accurately calculate your obligations
– Reduce packaging mass through procurement and design optimisation
– Improve recyclability ratings to lower fee rates
– Implement data systems that make compliance straightforward
– Turn EPR from a compliance burden into a controlled cost
Time to Get Clear on Where You Stand
The packaging EPR regulations aren’t going away. The sooner you understand your true position, the sooner you stop worrying about compliance and start optimising for cost and environmental performance.
If you’d like help assessing whether your business is affected and what your obligations are, I’m here to help. Drop me a message or comment below. I’ll point you in the right direction.
The worst position to be in isn’t knowing you have a compliance issue. It’s not knowing you don’t know.