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On 19th August 2026, Defra updated its guidance on what large producers must report under Extended Producer Responsibility (EPR) for packaging. The changes don't add new rules. They make clear who should report which packaging, so the same tonnage isn't reported twice or missed.
For many BHETA members, that clarity is overdue. If you sell own-brand housewares, small electrical appliances (SEA), DIY or garden products, import through an agent, or sell online, the guidance speaks directly to how your supply chain works. Here's what it means for your business.
Are you a large producer?
You are a large producer under EPR if your business has an annual turnover above £2 million and supplies more than 50 tonnes of packaging in the UK.
Large producers must register each year, report packaging data every six months, meet recycling obligations and pay waste disposal fees on household packaging. Below those thresholds, you may still be a small producer with lighter, annual duties.
Brand owners and importers
This is where duplicated reporting is most likely in our sectors. So many own-brand kettles, cookware, power tools and garden products are sourced overseas and brought in by a third party.
The guidance is clear. If you are a UK-based large producer and goods carrying your brand are imported on your behalf, you report that packaging under your brand. Your importer should not also report it as their own imports.
Importers do report packaging as imported where it is unbranded or not their brand, or where the brand owner is a small producer or based outside the UK.
Selling through online marketplaces
Marketplace operators report packaging on goods that non-UK sellers sell into the UK through their platform. They don't report packaging from UK-based sellers.
If you sell on Amazon, eBay, Wayfair or similar, your EPR obligations stay with you. The marketplace won't report your packaging for you.
Distributors and wholesalers
If you supply empty packaging, you report it unless a large producer will pack or fill it. To rely on that, check your customer's status on the public register of producers and keep a record.
What you should do now
A short review now could save a costly resubmission later. We suggest you:
- confirm whether you are a large or small producer
- map your import routes and agree in writing who reports what with agents and freight partners
- check partners and customers against the public register of producers
- make sure each tonne of packaging is reported under one activity only
How BHETA can help
EPR remains one of the biggest cost and admin pressures our members face. You don't have to work through it alone.
Our Business Support Provider (BSP) Wastepack is one of the UK's leading compliance schemes, with over 20 years' experience in producer responsibility. It can help you confirm your status, register and report your packaging data. Find out how Wastepack can support you.
We'll keep our EPR member guidance up to date as Defra's guidance develops. Got a question about your business? Contact the BHETA team at info@bheta.co.uk.
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