The five fulfilment charges that don't appear on the rate card
Goods-in, storage minimums, packaging, the picks after the first one, and what it costs to leave.
Compliance
Packaging EPR: most small sellers owe nothing, and pay for it anyway
The rules catch far fewer online sellers than the headlines suggest. The cost reaches almost all of them regardless, through the price of a box. Here is where the line actually sits.
Extended producer responsibility for packaging, usually shortened to EPR, moved the cost of recycling packaging onto the businesses that put it on the market. Since the fees began landing, it has become one of the most misread subjects in UK e-commerce. Sellers doing a few hundred orders a month are being told they need to register. Most of them do not.
This piece sets out the actual thresholds, what each group has to do, and the part that catches everybody out: the sellers who are exempt still pay, because the fee is already inside the price of their boxes.
We are packers, not compliance advisers. Everything below is drawn from the government's own guidance and linked at the end. Treat it as a map of where to look, not as advice on your own position.
The three tests, all of which must be true
A business has an EPR obligation only if all three of these apply. Not one, not two.
- Your business is established in the UK.
- You supplied or imported more than 25 tonnes of packaging in the UK in the previous calendar year.
- Your worldwide annual turnover was £1 million or more.
Miss any one and there is no obligation at all. That single fact removes most small sellers from the scheme, and it is the fact that the noise around EPR most often leaves out.
Where the line sits
| Packaging in the previous year | Turnover up to £1m | £1m to £2m | Over £2m |
|---|---|---|---|
| Under 25 tonnes | No obligation | No obligation | No obligation |
| 25 to 50 tonnes | No obligation | Small producer | Small producer |
| Over 50 tonnes | No obligation | Small producer | Large producer |
A small producer registers and reports once a year, and pays no waste management fees. The government's guidance says so plainly: only large producers pay waste disposal fees, and small producers do not have to buy packaging waste recycling notes. A small producer reports its January to December data by 1 April of the following year and keeps its records for seven years.
A large producer carries the real weight. Registration each year, packaging data every six months rather than annually, recycling notes to buy, an annual compliance certificate, and the waste disposal fees themselves.
Twenty five tonnes is a lot more packaging than it sounds
Tonnes are an unhelpful unit for anyone who thinks in orders, so here is the same threshold in the units you actually work in. Twenty five tonnes a year is roughly 2,083kg a month.
| Packaging per order, as it leaves | Orders a month before you reach 25 tonnes a year |
|---|---|
| 100g, a padded mailer and a label | about 20,800 |
| 200g, a small carton | about 10,400 |
| 300g, carton with void fill | about 6,900 |
| 500g, larger carton, more fill | about 4,100 |
| 1kg, heavy or double boxed | about 2,000 |
A seller shipping 1,000 orders a month in 300g of packaging is at roughly 3.6 tonnes a year, nowhere near the threshold. The turnover test usually bites first anyway, and both have to be true before anything applies.
Two cautions on that table. It counts all the packaging you put on the market, which includes the product's own retail box, not just the mailer it travels in. And if you import goods, packaging that arrives around them can count too. Weigh a real order as it leaves, product packaging included, rather than weighing an empty carton.
The part that reaches everyone
Here is the bit that matters for a business well under the thresholds. Your packaging suppliers are mostly not under them. The mills, converters and distributors who make and sell cartons, mailers and void fill are large producers, they carry the fees, and those fees are now a line in their cost base. You pay it in the price of a box rather than in a return to a regulator.
So the practical exposure for a small seller is not a compliance exposure at all. It is a purchasing one, and it responds to the same things it always did: buy the right size, carry fewer sizes, and stop shipping air.
The cheapest packaging decision is almost always the smallest box that still protects the product. It lowers the material you buy, the fee baked into it, and the parcel band you pay to ship it in, all at once.
What is worth doing, whichever side of the line you are on
- Weigh a typical order, packaging only, product packaging included. Multiply by your annual order count. You will usually settle the 25 tonne question in five minutes.
- Check the turnover test honestly, because it is worldwide turnover, not UK sales and not profit.
- Keep twelve months of packaging purchase records. If you are near the line in either direction, the records are what settles it, and large producers have to keep them for seven years anyway.
- Ask your packaging supplier what has moved and why. A supplier who cannot tell you which increases are EPR related and which are not is a supplier worth quoting against.
- Re-run your box sizes. Most sellers we take on arrive with two or three sizes and need five, and the cost of the missing sizes shows up in material, in void fill and in the parcel band.
Where we sit
We buy packaging in volume and pack to the smallest suitable size as a matter of course, so our clients get that benefit without running a purchasing exercise of their own. We are not a compliance service and will not tell you whether you are obligated. What we can do is tell you exactly what leaves the building around your product and what it weighs, which is the number the question actually turns on. Our rate card is published, packaging included.
If you want the wider picture of what a fulfilment arrangement really costs once packaging, storage and handling are counted, that is a separate piece: the five fulfilment charges that do not appear on the rate card.
Packaging EPR, answered
Do I have to register for packaging EPR if I sell online?
Only if all three tests are true at once: your business is established in the UK, you supplied or imported more than 25 tonnes of packaging in the UK in the previous calendar year, and your worldwide annual turnover was £1 million or more. Fail any one of them and you have no EPR obligation, whatever your order count looks like.
Do small producers pay EPR waste management fees?
No. GOV.UK is explicit that only large producers pay waste disposal fees, and small producers do not have to buy packaging waste recycling notes. A small producer registers with the environmental regulator and reports its packaging data, and that is the extent of it.
When does a small producer have to report packaging data?
A small producer reports the previous calendar year in one go, by 1 April of the following year. So January to December 2026 data is due by 1 April 2027. Large producers report twice a year instead.
What counts towards the 25 tonnes?
More than the outer box. It is the packaging your business supplies or imports, which includes the product's own retail packaging, the mailer or carton, void fill, tape and labels. Weigh a typical order as it leaves, including the product packaging, rather than weighing an empty box.
If a fulfilment partner buys and packs the boxes, is it their obligation?
Not automatically. The obligation follows the activity your business performs, such as being the brand owner or the importer, rather than who physically tapes the carton. Using a third party does not on its own move an obligation off you, so check your own position with the regulator's guidance.
Sources, all government guidance: who is affected and what to do, what you must do as a small producer and registering with the environmental regulator. Checked on 19 September 2026. Thresholds and deadlines change, so confirm your own position against the current guidance or with your accountant.
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