On January 1st, 2025, the Producer Responsibility Obligations (PROs) came into effect in the UK.

These obligations are designed to help reduce the amount of packaging material waste being generated, especially packaging that may be difficult to recycle, such as polythene or other plastics.

Additionally, these obligations facilitate the government’s ability to accurately assess the amount of waste generated by industrial and commercial enterprises.

Suppose businesses that fall within the scope of this legislation fail to register their waste usage and comply with the regulations. In that case, they may be subject to penalties, including potentially sizable fines.

Throughout this article, we will focus on packaging and packaging waste regulations. Specifically, we will be explaining:

Who is Within The Scope Of Packaging Waste Regulations?
Where Do Businesses Need To Register?
What Information Do Businesses Need to Provide?
What Happens If Businesses Fail To Register?

A Brief Guide To PROs for Packaging

Who Is Within The Scope Of Packaging Waste Regulations?

Under the new obligations, any business that generates a turnover above £1 million and produces over 25 tonnes of packaging material is considered to be ‘within the scope’ of the Producer Responsibility Obligations packaging waste regulations.

However, depending on the size of your organisation, this is further broken down into two categories:

Small Producers

The limit to be considered a ‘Small Producer’ is to generate less than £2 million a year in turnover and less than 50 tonnes of packaging material. Small Producers are required to track the amount of packaging they produce, but are not subject to additional charges.

Large Producers

Any business that generates over £2 million in turnover and over 50 tonnes of packaging material is considered a ‘Large Producer’. Large producers must register, track their packaging data, and assume financial obligations, including waste management fees, administrative costs, and registration charges.

Where Do Businesses Need To Register?

To register an account to report the volume of packaging and packaging waste regulation data, you can create an account on the government’s website. The government has also produced a guide explaining how to create and format a file for submission.

What Information Do Businesses Need to Provide?

All producers that are affected by these obligations must gather at least three key pieces of information. These pieces of information are:

Packaging Activity Data: This data indicates whether you are importing packaging, packing parcels using packaging materials, or producing your own packaging materials.
Packaging Class Data: The government recognises four types of packaging: primary, secondary, shipment or tertiary. The government provides definitions of these terms to facilitate easier data submission by businesses.
Packaging Material and Weight Data: This section outlines the overall volume and weight of the packaging material used.

In addition to these three pieces of information, Large Producers must also collect data on Packaging Data Type, for example, explaining whether this material is for domestic or non-domestic use. Small Producers don’t need to provide this, as they will only be submitting using two submission codes: SP (Small Organisation Packaging – all) and HDC (Household Drinks Containers).

How Do Businesses Comply With These Obligations?

Data reporting obligations have already been in place since 2023, so any businesses that are in-scope should have already gathered data for the 2024 period, ready to submit.

To meet ongoing compliance, businesses also need to:

Register with the appropriate environmental agency. A business can do this directly or by becoming a member of an appropriate compliance scheme
Submit data annually (for Small Producers) or every six months (for Large Producers), which details the amount of packaging used
Calculate their financial obligation (if applicable)

In addition, Large Producers must also:

Provide recycling information to consumers if packaging is supplied to end users.
Produce recycling evidence notes

What Happens If Businesses Fail To Register?

If businesses are found to be non-compliant with the relevant legislation, they may face criminal prosecution, as well as monetary fines.

What Is The Deadline For Businesses To Register And Submit Data?

The most recent deadline for submitting 2024 data was April 1st, 2025, for both Small and Large Producers.

The next deadline for Large Producers to submit their six-month data report for 2025 is October 1st, 2025, and the annual deadline for Small Producers is April 1st, 2026.

Find The Perfect Packaging Solution At Schott Packaging

Whatever your packaging needs will be for the next year, consider browsing our range of professional-grade packaging materials.

In addition to the fantastic variety and high-quality finish of our packaging products, we also provide free UK shipping on orders over £50 (+VAT), allowing you to save on shipping costs.If you have any questions about our packaging materials or are considering purchasing in bulk, please don’t hesitate to contact one of our friendly team members by filling out our online form or emailing us at info@schottpackaging.co.uk.

UK Businesses Could Face Fines If They Do Not Register for Producer Responsibility Obligations