United Kingdom vs Washington EPR: Rules Compared
Last verified
United Kingdom and Washington both run packaging EPR, but the rules differ. Both require producers to register. United Kingdom asks for its first annual report earlier, on April 1 against May 31 in Washington. Every figure below links to its primary source.
United Kingdom and Washington side by side
2 of 9 rows have a verified figure on each side of United Kingdom and Washington; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | United Kingdom | Washington | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | producer compliance schemes | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | none recorded; see thresholds | $5,000,000 | Not comparable |
| Lowest weight exemption | none recorded; see thresholds | 907.2 kg | Not comparable |
| First annual report date | April 1 | May 31 | United Kingdom |
| Published penalties | not yet published | 1 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 196 GBP/tonne | not yet published | Not comparable |
| Plastic fee, cheapest matched rate | 423 GBP/tonne | not yet published | Not comparable |
Both programmes require a producer to register, in United Kingdom and in Washington.
The earliest annual report date is April 1 in United Kingdom and May 31 in Washington, 60 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.
Who runs the programme in United Kingdom and Washington
Who collects and who the producer files with, in United Kingdom and then Washington.
| Aspect | United Kingdom | Washington |
|---|---|---|
| Regime | Extended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 | Washington Recycling Reform Act, chapter 70A.208 RCW |
| Regulator | Four environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets fees | Washington State Department of Ecology |
| Producers obligated | Yes | Yes |
| Registration | Required, Report packaging data (RPD) service, run by Defra and the regulators | Required, Producer registers with a PRO; the PRO registers with Ecology |
| Producer organisation | producer compliance schemes; membership optional | one producer responsibility organisation: Circular Action Alliance; membership required |
| Transfer of responsibility | Not allowed | not yet published |
| Revenue counted as | worldwide revenue, GBP, previous accounting year | worldwide gross revenue, USD, prior fiscal year |
| Who counts as the producer | other: manufacturer, importer, online marketplace; primary: brand owner, packer and shipper, importer, online marketplace, seller; secondary: brand owner, packer and shipper, importer, online marketplace, seller; service: brand owner, packer and shipper, manufacturer, importer, seller; shipping: brand owner, packer and shipper, importer, online marketplace, seller; tertiary: brand owner, packer and shipper, importer, online marketplace, seller | primary: manufacturer, brand licensee, brand owner, importer |
The two programmes are organised differently. United Kingdom uses producer compliance schemes; Washington uses one producer responsibility organisation. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What United Kingdom and Washington cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when United Kingdom or Washington has no verified entry for it in the dataset.
| Aspect | United Kingdom | Washington |
|---|---|---|
| Materials covered | aluminium, fibre based composite, glass, paper and card, plastic, steel, wood, other | packaging, paper products |
| Product classes covered | primary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packaging | packaging, paper |
| Excluded from scope | charities supplying or importing packaging | exempt materials |
| Sales channels addressed | retail, wholesale, online, online marketplace | physical retail, remote sale, other distribution |
| Producer duty: primary packaging | brand_owner; packer_shipper; importer; marketplace; seller | manufacturer; licensee; brand_owner; importer |
| Producer duty: secondary packaging | brand_owner; packer_shipper; importer; marketplace; seller | not yet published |
| Producer duty: tertiary packaging | brand_owner; packer_shipper; importer; marketplace; seller | not yet published |
| Producer duty: shipping packaging | brand_owner; packer_shipper; importer; marketplace; seller | not yet published |
| Producer duty: service packaging | brand_owner; packer_shipper; manufacturer; importer; seller | not yet published |
| Producer duty: other packaging | manufacturer; importer; marketplace | not yet published |
| Reporting categories | 8, material and packaging class | not yet published |
| Published targets | plastic_recycling_obligation 57 by 2026-12-31; plastic_recycling_obligation 59 by 2027-12-31; glass_recycling_obligation 76 by 2026-12-31; glass_recycling_obligation 78 by 2027-12-31; aluminium_recycling_obligation 62 by 2026-12-31; aluminium_recycling_obligation 63 by 2027-12-31; steel_recycling_obligation 81 by 2026-12-31; steel_recycling_obligation 82 by 2027-12-31; wood_recycling_obligation 46 by 2026-12-31; wood_recycling_obligation 47 by 2027-12-31; paper_board_fibre_composite_recycling_obligation 77 by 2026-12-31; paper_board_fibre_composite_recycling_obligation 79 by 2027-12-31 | not yet published |
| Exemption 1 | Charities that supply or import filled or unfilled packaging in the UK, excluding subsidiaries that trade for profit. | A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. |
| Exemption 2 | not yet published | Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. |
Thresholds and exemptions in United Kingdom and Washington
Every verified threshold United Kingdom and Washington publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| United Kingdom | packaging tonnage | 25 tonnes | registration trigger | packaging supplied or imported in the UK in the previous calendar year |
| United Kingdom | revenue | £1,000,000 | registration trigger | worldwide annual turnover |
| United Kingdom | packaging tonnage | 50 tonnes | reduced duty | with turnover above 1 million and up to 2 million pounds, an obligated producer is small; above 50 tonnes with turnover over 2 million pounds is large |
| Washington | packaging tonnage | 1 short ton | exempt below | covered materials introduced, most recent fiscal year |
| Washington | revenue | $5,000,000 | exempt below | global gross revenue, prior fiscal year |
United Kingdom exemption: Charities that supply or import filled or unfilled packaging in the UK, excluding subsidiaries that trade for profit. It does not have to be applied for.
Washington exemption: A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. It does not have to be applied for.
Washington exemption: Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. It does not have to be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
Fees per kilogram for shared materials
United Kingdom publishes per-kilogram rates in the dataset; Washington does not. The rows therefore show United Kingdom only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between United Kingdom and Washington would mean inventing a figure, and this page does not do that.
United Kingdom: the 2025-26 fee schedule of PackUK extended producer responsibility for packaging (base fees), effective June 27, 2025, is the source of the per-kilogram rates used on this page.
United Kingdom 2025-26: the category “Paper and card” is published at 196 GBP/tonne.
United Kingdom 2025-26: the category “Plastic” is published at 423 GBP/tonne.
United Kingdom 2025-26: the category “Glass” is published at 192 GBP/tonne.
Deadlines in United Kingdom and Washington
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| United Kingdom | report | October 1, 2026 | the first half of 2026 |
| United Kingdom | report | April 1, 2027 | the second half of 2026 |
| United Kingdom | report | April 1, 2027 | 2026-P0 |
| United Kingdom | registration | October 1, 2026 | not yet published |
| United Kingdom | registration | April 1, 2027 | not yet published |
| United Kingdom | other | January 31, 2027 | calendar year 2026 |
| Washington | other | March 1, 2026 | not yet published |
| Washington | report | May 31, 2026 | not yet published |
| Washington | registration | July 1, 2026 | not yet published |
| Washington | other | October 1, 2028 | not yet published |
| Washington | other | March 1, 2029 | not yet published |
| Washington | other | January 1, 2030 | not yet published |
| Washington | payment | February 15, 2031 | not yet published |
| Washington | payment | February 15, 2032 | not yet published |
The earliest annual report date is April 1 in United Kingdom and May 31 in Washington, 60 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.
Penalties in United Kingdom and Washington
What each side has published; a side without an amount says so.
Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day.
Report formats in United Kingdom and Washington
How the report file for United Kingdom compares with the one for Washington.
| Aspect | United Kingdom | Washington |
|---|---|---|
| Layout | UK EPR packaging data file (large and small producer) 2026 specification, GOV.UK page last updated 19 August 2026 | Washington interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) |
| Recipient | The four UK environmental regulators through the Report packaging data (RPD) service | Circular Action Alliance (Washington PRO) |
| How it is submitted | Report packaging data service on GOV.UK. The customer, as an approved person, uploads the CSV. A compliance scheme can do this on the producer's behalf. | CAA producer portal. The customer signs in and submits. |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 15 | 4 |
| Required columns | 6 of 15 | 4 of 4 |
| Weight unit | kg | lb |
| Period basis | half year | calendar year |
United Kingdom report specification: GOV.UK Report packaging data: create your reporting file, Table 1a (large producers) and Table 1b (small producers), with code tables 2 to 7
The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, United Kingdom or Washington
Plan around the earlier report date first. United Kingdom asks for its first annual report on April 1, before Washington, so its data has to be ready first.
Questions about comparing these two programmes
Is United Kingdom or Washington stricter on packaging EPR?
Both require producers to register. United Kingdom asks for its first annual report earlier, on April 1 against May 31 in Washington.
Do I register in both United Kingdom and Washington?
United Kingdom requires producers to register. Washington requires producers to register.
How do the fees per kilogram compare in United Kingdom and Washington?
The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.
Which deadline comes first, United Kingdom or Washington?
The earliest annual report date is April 1 in United Kingdom and May 31 in Washington, 60 days apart. United Kingdom leaves less time to prepare, so its data has to be ready first.
How these figures are made
Sources
- gov.uk (how to comply with packaging recycling obligations as a large producer) retrieved
Original wording: go to schedule 5 of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (as amended)
Original wording: A compliance scheme cannot pay your waste disposal fees for you.
Original wording: you must meet your recycling obligations, including submitting your certificate or statement of compliance, by 31 January 2027
Original wording: Packaging recycling targets 2025 to 2027
- gov.uk: epr for packaging what you must do as a small producer retrieved
Original wording: Each of the 4 nations of the United Kingdom has its own regulator. You’ll be reporting to and monitored by the regulator for your nation.
Original wording: the fee is: £1,303 if you register directly with your environmental regulator £696 if you register through a compliance scheme
Original wording: Compliance schemes are third parties that help organisations meet the EPR for packaging requirements.
Original wording: annual turnover of more than £1 million and supplies more than 25 tonnes and no more than 50 tonnes of packaging
- gov.uk: check if you must comply with epr for packaging 2 retrieved
Original wording: you supplied or imported more than 25 tonnes of packaging in the UK in the previous year
Original wording: you must get your annual turnover from the last accounts that were available before 7 April 2026.
Original wording: your annual turnover worldwide was £1 million or more
Original wording: Charities that supply or import filled or unfilled packaging in the UK are exempt from EPR for packaging requirements.
- legislation.gov.uk: 1 retrieved
Original wording: a brand owner; (ii) a packer/filler; (iii) an importer or first UK owner; (iv) a distributor; (v) an online marketplace operator;
- gov.uk (packaging data check reporting periods and submission deadlines) retrieved
Original wording: 1 January to 30 June 2026 1 October 2026
Original wording: 1 July to 31 December 2026 1 April 2027
Original wording: 1 January to 31 December 2026 1 April 2027
Original wording: you must register for EPR for packaging each year, and pay the applicable fees by 1 October.
Original wording: you must register for EPR for packaging each year, and pay a registration fee by 1 April.
- gov.uk: report packaging data create your reporting file retrieved
Original wording: Report the weight of the individual materials used in the packaging you have supplied. You must report each material type separately.
Original wording: Add a new row of data for each packaging activity and each type of packaging you need to report.
- circularactionalliance.org: washington retrieved
Original wording: required in the Recycling Reform Act
Original wording: By January 1, 2026 Washington Department of Ecology must establish and appoint the initial membership of the advisory council.
Original wording: July 1, 2026 Washington regulatory deadline for Producers to register with a PRO.
Original wording: By March 1, 2026 A PRO must register with Washington Department of Ecology on behalf of its producers.
Original wording: By May 31, 2026 Reporting (Interim State Addendum Signed & Simplified Reporting)
- app.leg.wa.gov: default retrieved
Original wording: After July 1, 2026, be a member of a producer responsibility organization registered in this state
Original wording: Has a global gross revenue, not including on-premises alcohol sales, for the prior fiscal year of
Original wording: the producer is the person that manufactures the item
Original wording: In their most recent fiscal year introduced less than one ton of covered materials
Original wording: Until January 1, 2031, less than $5,000,000
Original wording: "De minimis producer" means a producer that
Original wording: Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
Original wording: By October 1, 2028, and every five years thereafter, submit a plan that meets the requirements of this chapter
Original wording: Beginning March 1, 2029, a producer that is not a member in good standing with a registered producer responsibility organization
Original wording: By January 1, 2030, or within six months of plan approval, whichever is later, implement the plan approved by the department
Original wording: No less than 75 percent of the net costs by February 15, 2031
Original wording: No less than 90 percent of the net costs by February 15, 2032, and each year thereafter
Original wording: civil penalty of up to $1,000 per violation per day on any producer who violates this chapter
Original wording: "Covered material" means packaging and paper products introduced into the state.
- ecology.wa.gov: producer responsibility organization retrieved
Original wording: The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA.
- gov.uk (2025) retrieved
Original wording: This document provides base fees for year 1 (2025 to 2026) of the Extended Producer Responsibility (EPR) for packaging scheme.
Original wording: Paper and card 196
Original wording: Plastic 423
Original wording: Glass 192
The free plan is enough to start. We estimate and prepare; you sign and submit.