Josh Pitman, Managing Director at sustainable packaging firm Priory Direct, has warned that retailers are unprepared for Extended Producer Responsibility (EPR) rules around packaging, for which fees went live this month, with the firm fielding hundreds of customer queries.
EPR fees came into play from 1 October for ‘large’ producers including many affected retailers and Pitman, whose firm supplies planet-friendly packaging to more than 21,000 businesses, says: “The retail sector is simply not prepared for this shift in how their packaging data needs to be reported, and the fees payable based on weight, material and recyclability of packaging. This is particularly true of the ‘majority middle’, or those that fall just over the threshold.
“We know this because for many weeks, we’ve been dealing with between five and ten queries daily from our customers on our website chat function and directly to account managers. Many of these are basic questions like: does EPR apply to them, what data do they need to share, where do they get this from, and how do they reduce exposure to it? These are all basic but critical details that should have been established months ago, as reporting requirements have been in play since 2023.
“However, there appears to be a lack of clear, helpful guidance and limited proactive engagement with affected businesses from government, aside from some overly exclusive and expensive events featuring official spokespeople. Knowledge of how to navigate EPR is being firewalled by companies looking to profit from guiding larger clients through the change when, for it to make the most impactful change, the government should be providing clearer, more-open-access guidance on how to use this legislation to actually make a positive improvement to the impact of their business.”
He adds: “This means it is falling to the private sector to give practical support to retailers, who are seeing headlines like John Lewis revealing a £22 million cost through EPR and are rightly concerned. Without this support, these businesses would struggle to respond to EPR legislation and – what is most crucial – adopt more sustainable packaging choices to limit their exposure to the fees. Otherwise, there is a real risk that business will simply absorb the fees rather than do what EPR is designed to achieve, which is to spur a switch towards more environmentally friendly packaging.”
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. This definition encapsulates a wide range of businesses including many retailers.
‘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. Both small and large producers must report their packaging data, but currently only large producers need to pay fees. These producers will have received their very first invoice – or Notice of Liability (NoL) - this month, October 2025.
Pitman concludes: “This is a real opportunity for all retailers to minimise their exposure to EPR by switching to more sustainable alternatives. The cost of these alternatives is, in the majority of cases, the same or lower, as well as incurring lower EPR fees, and such steps also help to reduce the overall environmental impact of these retailers. This is a positive move at a time when legislative and consumer pressures on retailers around ESG are growing. With clearer, more practical guidance for those affected, EPR is the carrot that could make a dramatic difference to retailers’ impact on the planet.”
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.