Business Baron

What happens to the packaging after they leave

Packaging waste regulations now charge producers for disposal through EPR. What the thresholds are, plus the bag charge and business waste duty of care.

, Retail

A homeware shop flattens about sixty boxes a week. For years the owner put them out with the general waste and paid a small monthly charge to a firm that collected on Tuesdays.

Then two things happened. His waste contractor told him that from March 2025 he had to separate dry recyclables and food waste from residual waste, which meant more bins in a yard that has room for two. And an email arrived asking for his packaging data, because his turnover had crossed a threshold he had never heard of.

Neither change was large on its own. Together they added a cost line to a business that had never had one.

Extended producer responsibility charges you for what you put out there

The principle is that whoever puts packaging onto the market pays for its collection, sorting and disposal, rather than local authorities and their council tax payers.

In the United Kingdom this runs through the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 in England, Scotland and Northern Ireland, with Wales making its own equivalent, in force from 1 January 2025. The scheme administrator is PackUK, and the environmental regulators, including the Environment Agency in England, handle enforcement.

Whether you are caught depends on two tests together. You are a large producer if your annual turnover is £2 million or more and you supplied or handled 50 tonnes or more of packaging in a relevant year. You are a small producer if your turnover is between £1 million and £2 million, or your packaging is between 25 and 50 tonnes, subject to the detailed conditions. Small producers report data. Large producers report data and pay disposal fees.

The category you fall into also depends on what you do with packaging: whether you are a brand owner, an importer, a distributor, a seller under your own brand, or an online marketplace. A retailer selling only other people's branded goods has a different obligation from one selling its own label, which is one more thing to price in before launching an own brand range.

Fees are being modulated by how recyclable the packaging is, so material choice moves from an aesthetic decision to a cost decision. Packaging that is hard to recycle attracts a higher fee than packaging that is not. If you design your own boxes, bags or jars, that is now a line in the business case.

A deposit return scheme for single-use drinks containers is due to launch in October 2027 in England, Scotland and Northern Ireland, with Wales taking a different path. If you sell drinks, that will change your obligations again, potentially including acting as a return point.

The charges and taxes attached to specific materials

Three separate mechanisms sit alongside the main producer responsibility regime, and they have different triggers.

The single-use carrier bag charge in England is a minimum of 10p and, since 21 May 2021, applies to all retailers rather than only those with 250 or more employees. Wales introduced its charge in 2011, Scotland in 2014 and Northern Ireland in 2013, each with its own rules and current rate. You must keep records of the bags you supply and the proceeds, and the expectation is that the net proceeds go to good causes. The record keeping requirement is the part small shops most often miss.

Plastic Packaging Tax applies to plastic packaging manufactured in or imported into the United Kingdom containing less than 30% recycled plastic, where you manufacture or import 10 tonnes or more in a twelve month period. It began in April 2022 at £200 per tonne and has been uprated in subsequent years, so check the current rate with HMRC. If you import goods packaged in plastic, the packaging may be in scope even though the product is not.

Single-use plastic bans are separate again. England banned the supply of single-use plastic plates, bowls, trays, cutlery and expanded polystyrene food and drink containers from 1 October 2023, and Wales and Scotland have their own bans covering broadly similar items on their own timetables. If you have stock in the stockroom from before a ban, the ban applies to supplying it, not to when you bought it.

Your own waste is a duty, not a service you buy

Everything above concerns packaging you put into the market. The cardboard in your yard is governed by a different regime and by a duty you cannot contract out of.

Section 34 of the Environmental Protection Act 1990 imposes a duty of care on anyone who produces, imports, carries, keeps, treats or disposes of controlled waste. In practice that means you must store waste securely so it cannot escape, transfer it only to an authorised person, and complete a waste transfer note describing the waste and keep it for two years.

Authorised person means a registered waste carrier. You can and should check your contractor's registration on the public register maintained by the environmental regulator. If your waste is fly-tipped by somebody you handed it to without checking, the duty of care failure is yours, and "he had a van and seemed fine" is not a defence. The same applies to the man who offers to take your old fridges away for £20.

Separate collection has now been layered on top. In England, Simpler Recycling requires workplaces to separate dry recyclable materials, glass, metal, plastic, paper and card, and food waste from residual waste. Businesses with 10 or more full time equivalent employees came into scope on 31 March 2025, with micro-firms of fewer than 10 following on 31 March 2027. Wales brought in its Workplace Recycling Regulations from 6 April 2024, with a stricter separation requirement and specific rules on food waste and on unsold textiles and electricals. Scotland has required separate collection of key materials since 2014.

The practical consequences are physical. More containers in a yard sized for fewer. A back door route that has to work for a member of staff carrying food waste past the stock. A contract that needs renegotiating, because contractors have repriced around the new streams.

The offsetting gain is real if you use it. Clean, baled cardboard has a value, and a shop generating enough of it can move from paying for collection to being paid, or at least to a much lower charge. That only works if the material is genuinely uncontaminated, which is a staff habit rather than a purchasing decision.

Where this shows up in the game

Shops and food producers are part of Business Baron's full game, and e-commerce is free to run. A career in the game lives through decades of rule changes, so the regimes a business answers to are not the same at the end as at the start. A cost you carry twice is still a cost, and the monthly figures count both.

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