Plastic Packaging Tax and packaging EPR compared

Plastic Packaging Tax is an HMRC tax on plastic packaging components made in or imported into the UK with less than 30% recycled plastic, paid by the manufacturer or importer at a flat rate per tonne. Extended producer responsibility for packaging is an environmental regime run by the UK environmental regulators and PackUK that covers every packaging material and falls mainly on brand owners, importers and sellers. The same plastic tray can attract both, but each has its own threshold, its own data and its own deadlines.

What is each charge for?

Plastic Packaging Tax was introduced on 1 April 2022 by Part 2 of the Finance Act 2021. Its aim is to encourage recycled content: a component with 30% or more recycled plastic is not taxed, and everything else is charged at £228.82 per tonne from 1 April 2026. The money goes to HMRC like any other tax. Our main Plastic Packaging Tax guide covers the charge in detail.

Extended producer responsibility (EPR) for packaging sits under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. It moves the cost of managing packaging waste onto the businesses that place packaging on the market. Large producers must fund recycling by acquiring packaging waste recycling notes (PRNs) or export recycling notes (PERNs), and pay waste disposal fees to PackUK on household packaging. The government says the scheme will secure £1.4 billion for local authorities in the 2025/26 financial year.

Who pays each charge?

The two regimes look for different people in the same supply chain.

• Plastic Packaging Tax is paid by the business that carries out the last substantial modification of a component in the UK, or the person on whose behalf finished components are imported (sections 43 and 44 of the Finance Act 2021). A brand owner that buys finished packaging from a UK converter usually has no tax to pay itself.
• EPR applies to a producer of packaging, meaning a business that supplies filled packaging under its own brand, packs or fills goods, imports goods in packaging, supplies unfilled packaging it makes or imports, hires out reusable packaging, operates an online marketplace supplying packaging into the UK from abroad, or sells filled packaging to an end user. Where another business packs or imports goods in your branded packaging, you remain the producer.

So a UK converter making plastic trays may pay Plastic Packaging Tax on them while the supermarket brand that fills and sells them carries the EPR obligation.

How do the thresholds compare?

	Plastic Packaging Tax	Packaging EPR
Materials	Plastic only	All packaging materials
Tonnage test	10 tonnes of finished plastic components in the past 12 months or expected in the next 30 days	More than 25 tonnes of packaging supplied or imported in the previous calendar year
Turnover test	None	£1 million or more worldwide; large producers over 50 tonnes and over £2 million
Residence	UK and overseas businesses can be liable	Must be established in the UK
Regulator	HMRC	Environment Agency, Natural Resources Wales, SEPA or NIEA, with PackUK collecting disposal fees

For 2026 EPR data, the tonnage test uses packaging supplied or imported from 1 January to 31 December 2025, and turnover comes from the last accounts available before 7 April 2026, using audited accounts if you publish them. Charities are exempt from EPR, though their trading subsidiaries are not.

What data does each regime need?

Plastic Packaging Tax

Returns are quarterly. They report, in kilograms rounded down, the weight of finished components made and imported, the weight with 30% or more recycled plastic, medicine packaging, and components exported or converted. Records are kept by product line for six years and must show how recycled content was worked out and evidenced. Weights must come from one of HMRC’s approved weighing methods; estimates are not one. The return mechanics are in Plastic Packaging Tax returns and deadlines.

EPR

EPR data is reported through the report packaging data service by material and by packaging activity, with weights in kilograms. Large producers report every six months, with deadlines of 1 October for January to June and 1 April for July to December; small producers report the previous calendar year once by 1 April. Large producers also have to separate household from non household packaging, because disposal fees are charged only on household packaging. EPR data must be kept for seven years, and resubmitting data after the deadline can cost £807, or £512 for a producer registered through a compliance scheme.

How is the cost worked out?

Plastic Packaging Tax is a single rate per tonne on chargeable plastic, with the 30% recycled content test acting as an on or off switch for each component.

EPR costs come from several elements:

• Registration fees. A small producer pays £1,216, or £631 if registered through a compliance scheme.
• Recycling obligations. Large producers must acquire PRNs or PERNs equal to a percentage of the packaging they placed on the market. The 2026 business target for plastic is 57%.
• Waste disposal fees. Large producers pay PackUK on household packaging under an annual notice of liability, usually in quarterly instalments. For packaging placed on the market in 2024, invoiced from October 2025, the base fee for plastic was £423 per tonne. The notice of liability can adjust the per tonne fee for a packaging’s environmental impact, which PackUK calls modulation.

The two regimes measure environmental performance differently. Plastic Packaging Tax looks only at recycled content, while EPR fee modulation looks at the packaging’s environmental impact. A tray with 30% recycled plastic escapes the tax but still carries EPR costs for an obligated producer.

How do the two charges combine for one business?

Illustration only. A UK company imports filled drinks under its own brand. In 2025 it imported 60 tonnes of plastic packaging, all with less than 30% recycled content, and its worldwide turnover was £5 million. It expects the same volume in 2026.

• Plastic Packaging Tax: it is the importer, so it must register and pay. If 60 tonnes arrive in the 2026 to 2027 tax year, the tax is 60 × £228.82 = £13,729.20.
• EPR: with more than 50 tonnes and more than £2 million turnover it is a large producer. It must register each year, report every six months, acquire plastic PRNs or PERNs for 57% of 60 tonnes, rounded to 34 tonnes, and pay disposal fees on the household share.

Moving to bottles with 30% recycled content would remove the tax but leave the EPR obligations in place.

What mistakes do businesses make?

• Assuming that being outside one regime means being outside the other. The 10 tonne plastic test and the 25 tonne all materials test catch different businesses.
• Using one data set for both. Plastic Packaging Tax counts finished plastic components by quarter; EPR counts all materials by calendar period and by packaging activity.
• Expecting a compliance scheme to pay PackUK disposal fees. The guidance says a compliance scheme cannot pay the notice of liability for you.
• Forgetting that imported transport packaging such as pallet wrap is outside Plastic Packaging Tax; see Plastic Packaging Tax exemptions.

Plastic Packaging Tax sits alongside other environmental taxes such as Landfill Tax.

If HMRC opens a check into your return, tax investigation insurance pays your accountant’s fees. Solar Protect cover pays up to £100,000 with no excess; it never pays tax, interest or penalties. Read how our cover works or get a quote.

Related Accountapedia entries

• Plastic Packaging Tax for importers
• Joint liability for Plastic Packaging Tax
• The UK carbon border adjustment mechanism
• The Soft Drinks Industry Levy
• The Aggregates Levy

Sources

• GOV.UK: Check if you need to register for plastic packaging tax
• legislation.gov.uk: Act 2021 c. 26, section 44
• legislation.gov.uk: SI 2024/1332
• GOV.UK: Check if you must comply with epr for packaging 2
• GOV.UK: Extended producer responsibility for packaging recycling obligations a
• GOV.UK: Packaging data check reporting periods and submission deadlines
• GOV.UK: Epr for packaging what you must do as a small producer
• GOV.UK: Extended producer responsibility for packaging notice of liability
• GOV.UK: Year 1 extended producer responsibility for packaging fees update
• GOV.UK: Completing your plastic packaging tax return

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.