Extended producer responsibility (EPR) explained: the UK, the EU and Asia

EPR often comes up in conversations about plastic credits, and it causes confusion. Is a credit a way to meet EPR? Does EPR make credits unnecessary? Both are fair questions. This guide sets out what EPR is, how it works in the places that matter most to UK businesses and to the countries where we work, and where credits fit.

If you are new to plastic credits, start with What is a plastic credit?.

Play video: EPR Explained: Extended Producer Responsibility in the UK, EU and Asia3 min

What EPR means

The OECD describes extended producer responsibility as a policy approach that makes producers responsible for their products along the entire life cycle, including after consumers throw them away. In practice that usually means one or more of three things:

• Paying for the collection, sorting and recycling of the packaging you place on the market.
• Meeting targets for how much of that packaging is recovered or recycled.
• Reporting what you sell, by material and weight.

Many schemes also adjust fees so that packaging that is easier to recycle costs less. That gives producers a reason to change design, not only to pay.

EPR in the UK

A UK business that sells packaged goods deals with this system directly.

Who is affected. An organisation has obligations if it supplied or imported more than 25 tonnes of packaging in the UK in the previous year and has a turnover of £1 million or more. A large producer handles more than 50 tonnes and has a turnover above £2 million. Others above the first threshold are small producers.

What small producers do. Register with their environmental regulator, report packaging data once a year and keep records for seven years.

What large producers do.

1. Register each year and report packaging data every six months.

2. Meet recycling obligations by acquiring packaging waste recycling notes (PRNs and PERNs) from accredited reprocessors and exporters, material by material.

3. Pay a waste disposal fee for household packaging to PackUK, the scheme administrator, which sets the fee rates.

4. Submit a certificate of compliance each year.

Fees. The first fees, for the year from 1 April 2025 to 31 March 2026 and based on 2024 packaging data, were invoiced from October 2025. From 2026-27, PackUK modulates fees using a recyclability rating of red, amber or green, based on 2025 data. Red packaging costs more and green costs less. PackUK says modulation does not raise the total of household packaging fees; it changes how they are shared.

Alongside EPR. The Plastic Packaging Tax is a separate charge on plastic packaging with less than 30% recycled content. Our guide to buying plastic credits responsibly explains why credits reduce neither the tax nor EPR fees.

EPR in the EU

The EU's Packaging and Packaging Waste Regulation (EU) 2025/40 entered into force on 11 February 2025 and generally applies from 12 August 2026, replacing the 1994 Packaging Directive. It aims to make all packaging on the EU market recyclable in an economically viable way by 2030 and to increase the use of recycled plastic in packaging.

A UK business selling packaged goods into the EU should check its obligations in each country where it sells. The EU also bans certain environmental claims based on offsetting under Directive 2024/825, covered in our buying guide.

EPR in Asia

India. The Plastic Waste Management (Amendment) Rules 2022 require producers, importers and brand owners to register on a national portal run by the Central Pollution Control Board and meet rising targets, partly by acquiring EPR certificates from registered processors. These certificates are compliance instruments, not voluntary credits.

The Philippines. The Extended Producer Responsibility Act of 2022 requires large companies to recover a rising share of their plastic packaging, from 20% in 2023 to 80% from 2028. The rules allow offsetting and some compliance schemes use plastic credits.

Our article on plastic credits in India and the Philippines covers both systems in detail.

Vietnam. Decree 08/2022/ND-CP brought in recycling responsibility for packaging from 1 January 2024. Producers and importers either recycle a set share of what they sell or pay into the Vietnam Environment Protection Fund. The rules have been amended since, so check the current version.

Indonesia. Ministerial Regulation P.75/2019 asks producers, retailers and food service businesses to follow a waste reduction roadmap from 2020 to 2029, with a target of cutting the waste from their products and packaging by 30%. Producers submit plans to the environment ministry.

EPR and plastic credits: how they differ

The two meet in some places. In the Philippines, the law itself allows offsetting, and some compliance schemes use credits. In India, the EPR certificate system runs separately from voluntary credits. Wherever both exist, the same tonne must not be counted twice: once for a producer's legal target and again as a credit sold to someone else.

Where credits fit

EPR covers your own packaging in your own market. Credits can fund collection where EPR is new, weak or missing, often in the places where plastic is most likely to leak. They work best alongside a company's own efforts to reduce its impact, and businesses still need to reduce the plastic they use.

When a company asks me about credits, I start by asking what it wants to achieve. If the goal is compliance in the UK, the answer is EPR, not credits. If the goal is to fund collection beyond your legal duties, credits can help, as long as you describe them accurately.

Questions to ask

1. Which EPR rules apply to us, in which countries?

2. Are we a small or large producer in the UK, and what does that require?

3. How does our packaging score on recyclability, and what would change the rating?

4. If we buy credits, could the same tonnes count towards someone's EPR target?

5. Are we describing our credits as anything other than voluntary support?

Frequently asked questions

Published by Reclaimed Earth Limited (Companies House 17392812), which works with plastic recovery projects in India, Indonesia and the Philippines and has a commercial interest in plastic credits. Edited with the Reclaimed Earth editorial team. Last updated 20 October 2026.