New Extended Producer Responsibility (EPR) rules may pose an existential risk to smaller retailers if packaging suppliers refuse to sell to them to reduce their own exposure to fees, warns packaging firm MD.
Josh Pitman, Managing Director at sustainable packaging firm Priory Direct, has warned that with new fees introduced in October 2025, ‘large producers’ such as national retailers, will pay fees based on weight, material and recyclability of their packaging, however, for retailers turning over less than £1 million it falls to their packaging suppliers to absorb this cost. This is acting as a deterrent to supplying smaller businesses.
Pitman, whose firm supplies planet-friendly packaging to more than 21,000 businesses, explains: “The EPR scheme has the best intentions by making those businesses that use the most packaging pay for it based on how environmentally friendly it is. However, for start-ups or small businesses, like independent retailers in our communities, they don’t qualify for the new fees and it is the packaging suppliers that, in effect, pick up their EPR costs.
“We are already seeing this have a negative impact with packaging suppliers reacting by cutting out these smaller clients. They are implementing this by introducing higher minimum order quantities (MOQs) or increasing the minimum spend on annual contracts. This could have a detrimental effect on smaller businesses and those looking to grow. They will either have to order in volumes that far exceed their needs, which is not cost efficient, or find alternative solutions that are likely to be prohibitively expensive and less environmentally friendly.”
Extended Producer Responsibility has changed the way UK organisations responsible for packaging must carry out their recycling responsibilities. For the purposes of EPR, packaging is defined as any material that is used to cover or protect goods that are supplied and that makes handling and delivering goods easier and safer. It includes anything that’s designed to be filled at the point of sale, such as a coffee cup.
‘Producers’ are defined as either ‘small’, with annual turnover above between £1 and £2 million and importing or supplying 25 to 50 tonnes of packaging, or ‘large’, with a turnover above £2 million and importing or supplying more than 50 tonnes of packaging. Large producers will have received their very first invoice – or Notice of Liability (NoL) - in October 2025. Businesses that fall beneath these thresholds do not have to supply packaging data or pay EPR fees. Their packaging will form part of their packaging suppliers’ data against which the supplier must pay EPR fees.
Pitman concludes: “It is a positive step that EPR is creating a financial incentive for businesses to make more environmentally friendly packaging choices but we have to ensure that legislation doesn’t negatively impact small or growing businesses that still need packaging to operate. At Priory Direct, we have minimised our exposure to EPR through being proactive on best practice so that we pay the lowest possible fees. We will continue to support businesses of all sizes.”
Priory Direct is based in Kent (Aylesford) and supplies sustainable packaging to over 21,000 businesses. It helps large retailers reduce their carbon footprint by tackling supply chain and operational challenges, helping to lower the environmental impact of ecommerce.
It also provides affordable, sustainable packaging materials to thousands of small businesses, with 2,000 products ranging from cardboard boxes to mailing bags. The company’s Priory Elements range is designed with recyclability in mind and is partnered with international organisation 1% For the Planet. The firm has numerous charitable partnerships, is carbon neutral, a B Corp, and working towards net neutrality.