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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.

Paired bars comparing how many verified thresholds, deadlines and penalties United Kingdom and Washington publish, and how many columns their report layouts hold.United Kingdom / Washington (published items): Thresholds: United Kingdom 3, Washington 2; Deadlines: United Kingdom 6, Washington 8; Penalties: United Kingdom 0, Washington 1; Report columns: United Kingdom 15, Washington 4United KingdomWashingtonpublished items051015Thresholds32Deadlines68Penalties01Report columns154
Source: United Kingdom and Washington primary sources, retrieved 2026-11-05

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.

United Kingdom and Washington: the measures both programmes publish
MeasureUnited KingdomWashingtonStricter
Registration dutyRequiredRequiredSame
Producer organisationproducer compliance schemesone producer responsibility organisationNot comparable
Lowest revenue exemptionnone recorded; see thresholds$5,000,000Not comparable
Lowest weight exemptionnone recorded; see thresholds907.2 kgNot comparable
First annual report dateApril 1May 31United Kingdom
Published penaltiesnot yet published1 publishedNot comparable
Report filecsvcsvNot comparable
Paper fee, cheapest matched rate196 GBP/tonnenot yet publishedNot comparable
Plastic fee, cheapest matched rate423 GBP/tonnenot yet publishedNot 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.

United Kingdom and Washington: how each programme is set up
AspectUnited KingdomWashington
RegimeExtended producer responsibility (EPR) for packaging, under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024Washington Recycling Reform Act, chapter 70A.208 RCW
RegulatorFour environmental regulators (Environment Agency, Natural Resources Wales, SEPA, NIEA); PackUK is the scheme administrator that sets feesWashington State Department of Ecology
Producers obligatedYesYes
RegistrationRequired, Report packaging data (RPD) service, run by Defra and the regulatorsRequired, Producer registers with a PRO; the PRO registers with Ecology
Producer organisationproducer compliance schemes; membership optionalone producer responsibility organisation: Circular Action Alliance; membership required
Transfer of responsibilityNot allowednot yet published
Revenue counted asworldwide revenue, GBP, previous accounting yearworldwide gross revenue, USD, prior fiscal year
Who counts as the producerother: 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, sellerprimary: 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.

Scope, producer duties, categories, labelling and targets, United Kingdom and Washington
AspectUnited KingdomWashington
Materials coveredaluminium, fibre based composite, glass, paper and card, plastic, steel, wood, otherpackaging, paper products
Product classes coveredprimary packaging, secondary packaging, shipment packaging, tertiary packaging, reusable packagingpackaging, paper
Excluded from scopecharities supplying or importing packagingexempt materials
Sales channels addressedretail, wholesale, online, online marketplacephysical retail, remote sale, other distribution
Producer duty: primary packagingbrand_owner; packer_shipper; importer; marketplace; sellermanufacturer; licensee; brand_owner; importer
Producer duty: secondary packagingbrand_owner; packer_shipper; importer; marketplace; sellernot yet published
Producer duty: tertiary packagingbrand_owner; packer_shipper; importer; marketplace; sellernot yet published
Producer duty: shipping packagingbrand_owner; packer_shipper; importer; marketplace; sellernot yet published
Producer duty: service packagingbrand_owner; packer_shipper; manufacturer; importer; sellernot yet published
Producer duty: other packagingmanufacturer; importer; marketplacenot yet published
Reporting categories8, material and packaging classnot yet published
Published targetsplastic_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 2027-12-31not yet published
Exemption 1Charities 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 2not yet publishedRegistered 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.

Verified thresholds in United Kingdom and Washington
PlaceMeasureAmountEffectBasis as published
United Kingdompackaging tonnage25 tonnesregistration triggerpackaging supplied or imported in the UK in the previous calendar year
United Kingdomrevenue£1,000,000registration triggerworldwide annual turnover
United Kingdompackaging tonnage50 tonnesreduced dutywith 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
Washingtonpackaging tonnage1 short tonexempt belowcovered materials introduced, most recent fiscal year
Washingtonrevenue$5,000,000exempt belowglobal 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.

Verified deadlines in United Kingdom and Washington
PlaceKindDateCovers
United KingdomreportOctober 1, 2026the first half of 2026
United KingdomreportApril 1, 2027the second half of 2026
United KingdomreportApril 1, 20272026-P0
United KingdomregistrationOctober 1, 2026not yet published
United KingdomregistrationApril 1, 2027not yet published
United KingdomotherJanuary 31, 2027calendar year 2026
WashingtonotherMarch 1, 2026not yet published
WashingtonreportMay 31, 2026not yet published
WashingtonregistrationJuly 1, 2026not yet published
WashingtonotherOctober 1, 2028not yet published
WashingtonotherMarch 1, 2029not yet published
WashingtonotherJanuary 1, 2030not yet published
WashingtonpaymentFebruary 15, 2031not yet published
WashingtonpaymentFebruary 15, 2032not 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.

Report file layouts for United Kingdom and Washington
AspectUnited KingdomWashington
LayoutUK EPR packaging data file (large and small producer) 2026 specification, GOV.UK page last updated 19 August 2026Washington interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance)
RecipientThe four UK environmental regulators through the Report packaging data (RPD) serviceCircular Action Alliance (Washington PRO)
How it is submittedReport 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 typecsvcsv
Encodingutf-8utf-8
Delimiter,,
Decimal separator.
Columns154
Required columns6 of 154 of 4
Weight unitkglb
Period basishalf yearcalendar 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

Our reviewers.

Sources

  1. 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
  2. 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
  3. 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.
  4. 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;
  5. 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.
  6. 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.
  7. 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)
  8. 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.
  9. 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.
  10. 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
Model both: United Kingdom and WashingtonCompare another pair

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