Food & Drink EPR Compliance
From plastic trays to glass bottles, food and drink businesses handle high volumes of diverse packaging. We make tracking and reporting it manageable.
Food & Drink EPR: What You Need to Know
The food and drink industry is the largest user of packaging in the UK, making EPR compliance particularly important — and potentially costly — for businesses in this sector. From plastic trays and glass jars to flexible films and aluminium cans, food businesses typically handle the widest range of packaging materials of any industry.
One of the biggest challenges for food and drink businesses is multi-material packaging. Modern food packaging often combines multiple materials for freshness and safety: a ready meal might come in a PET tray with a cardboard sleeve and a plastic film lid. Under EPR regulations, each material must be separated and reported individually by weight. A ready meal with a 15g plastic tray, a 10g card sleeve, and a 3g plastic film lid is three separate data entries.
Beverage producers face additional considerations. The UK's Deposit Return Scheme (DRS) may apply to certain drink containers, and the interaction between DRS and EPR obligations can be confusing. If your products are covered by DRS, they may be excluded from certain EPR reporting requirements. Our platform helps you navigate these overlapping obligations and ensure you are not double-reporting.
For food importers, EPR responsibility falls on the business bringing products into the UK. If you import finished food products — whether canned goods from Italy, wine from France, or snack foods from the US — you become the obligated producer for all packaging on those products. You need to obtain accurate packaging specifications from your overseas suppliers, including per-unit weights broken down by material type.
Seasonal variation is a major factor for food businesses. Easter chocolate packaging, Christmas hampers, summer barbecue ranges, and promotional multi-packs all create spikes in packaging volume that must be accurately captured in your quarterly reports. Many food businesses find their Q4 packaging volume is 2-3 times higher than Q1, making year-round tracking essential rather than annual estimation.
The modulated fee structure within EPR has significant implications for food packaging choices. Flexible plastic films (such as crisp packets and flow-wrap) are among the hardest packaging types to recycle, and are expected to attract higher fees. Businesses that can switch to recyclable mono-material alternatives — such as paper-based wraps or fully recyclable plastic — may see meaningful fee reductions. This creates both a compliance obligation and a commercial incentive to rethink packaging design.
Food safety requirements add another dimension. Unlike other sectors, food businesses cannot always choose the most easily recyclable packaging — food contact regulations, shelf life requirements, and supply chain conditions all constrain material choices. Our platform understands these sector-specific constraints and helps you optimise within them.
The 2025-2026 EPR fee rates are particularly relevant for food and drink businesses. The confirmed base fees per tonne are: glass at £192, paper and card at £196, steel at £259, aluminium at £266, plastic at £423, and fibre-based composite at £461. A food producer handling 15 tonnes of glass jars, 8 tonnes of cardboard, and 3 tonnes of steel cans would face annual EPR fees of approximately £5,225. From 2026-2027, fees will be modulated via DEFRA's Recyclability Assessment Methodology (RAM), making hard-to-recycle flexible plastics even more expensive.
Food and drink businesses with annual turnover of £1 million or more and handling 25 or more tonnes of packaging must comply. Large producers (turnover £2 million+ AND more than 50 tonnes) report every 6 months — H1 data by 1 October, H2 data by 1 April. Small producers report annually with data due by 1 April. Charities are exempt. All submissions go through DEFRA's RPD portal, administered by PackUK.
Common Food & Drink Packaging
These are the key packaging types you need to track and report for EPR compliance in the food & drink sector.
Plastic Trays & Punnets
PET trays for fresh food, punnets for fruit, and moulded packaging for ready meals. Often multi-material with film lids that must be reported as separate components.
Cardboard & Cartons
Cereal boxes, pizza boxes, egg cartons, and corrugated transit cases. Paper and card is typically the largest material category by weight for food businesses.
Cans & Tins
Steel and aluminium cans for beverages and tinned food. Different metals have different recycling rates and EPR fee structures. Report steel and aluminium separately.
Glass Bottles & Jars
Sauce bottles, jam jars, olive oil bottles, and beer/wine bottles. Glass is heavy and significantly impacts your fee calculations. May also fall under DRS.
Flexible Plastic
Cling film, crisp packets, bread bags, and flow-wrap packaging. Often the hardest to recycle and may attract higher modulated EPR fees.
Labels & Sleeves
Paper labels, plastic sleeve wraps, and multi-pack shrink bands. Small individually but significant at volume across product lines.
What You Need to Do
As a food & drink business handling packaging, you have specific EPR obligations under the UK's Extended Producer Responsibility scheme. Here is what you need to track and report to stay compliant.
- Report packaging by material type and packaging category (primary, secondary, transit)
- Track multi-material packaging components separately
- Account for seasonal and promotional packaging variations
- Report beverage container packaging under the Deposit Return Scheme if applicable
- Include labelling and sleeve weight in your packaging data
- Keep supplier packaging specifications on file for audit readiness
Do you need to comply?
You are obligated if your business:
- • Has an annual turnover exceeding £1 million
- • Handles more than 25 tonnes of packaging per year
- • Performs any of the obligated activities (manufacturing, importing, selling, hiring)
Even small producers below these thresholds must register as small producers under the National Packaging Waste Database (NPWD).
Common Food & Drink Compliance Mistakes
Avoid these frequent pitfalls that catch out food & drink businesses every year.
Not separating multi-material packaging
A food tray with a cardboard sleeve and a plastic film lid is three separate materials. Each must be reported individually by weight. This is one of the most common errors in food sector EPR reporting.
Underestimating flexible plastic weight
Cling film, crisp packets, and bread bags feel weightless, but at scale they add up to significant tonnage. Use supplier spec sheets to get accurate per-unit gram weights.
Confusing primary and transit packaging
The cardboard box a consumer takes home is primary packaging. The pallet wrap used in the warehouse is transit packaging. They are reported differently under DEFRA's categories.
Missing seasonal or promotional packaging
Limited edition packaging, seasonal gift boxes, and promotional sleeves are all reportable. Track them even if they are one-off runs or short-term promotions.
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