Packaging EPR applicability for a small UK producer
Name obligation year Y, packaging reference year Y-2, the 7 April cutoff in Y-1, and the latest financial year ending before that cutoff for which accounts are available at a stated assessment date. Large is more than £2 million and more than 50 tonnes. Small is more than £1 million and more than 25 tonnes and not large. Exactly those amounts are not more than. Completing the row is not registration, not a Report packaging data file and not a fee.
Download the blank worksheet. Packaging materials and disposal routes stay on the packaging guide. Plastic Packaging Tax remains a separate HMRC 10-tonne test. Retail packaging duties sit beside this applicability tree. The SME table points here for packaging EPR.
This worksheet is not registration and not the GOV.UK table
Name obligation_year as year Y in regulation 24 of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. packaging_reference_year must be calendar year Y-2. statutory_accounts_cutoff is 7 April in year Y-1. assessment_date is the date the row is assessed. accounts_available is yes, no or missing at that assessment date under regulation 24(5): for a body corporate under a duty to deliver annual accounts, yes only when those accounts have been delivered to the registrar; for a person not required to produce audited accounts, yes when accounts are available. Identify the accounts_record used. accounts_period_end is the latest financial year that ended before the cutoff for which accounts_available is yes. Do not automatically use a later financial year whose accounts are not available. Accounts need not have become available before the cutoff. year_alignment is matches_reg24 only when the packaging year is Y-2, the accounts period is that latest qualifying year, and accounts_available is yes; otherwise does_not_match or missing. Missing accounts_available keeps producer_class waiting. Do not treat the financial-year end as the cutoff.
GOV.UK’s 19 August 2026 page describes reporting 2026 packaging data using calendar 2025 packaging and accounts available before 7 April 2026. That is a data-reporting-year explanation. This sheet uses regulation 24’s obligation-year structure and paragraph (5) availability at the assessment date. If the years and availability cannot be aligned to regulation 24, leave producer_class waiting.
established_in_uk is yes, no or missing. No is outside_this_sheet, not a claim that no EPR duty exists anywhere. producer_activity is brand_fill, pack_or_fill, import, unfilled_supply, reusable_hire, online_marketplace, selling_filled, none, unverified or missing. none is outside_this_sheet because there is no relevant packaging activity. unverified or missing keeps producer_class waiting. charity_exemption is yes only for a charity supplying or importing packaging that is not a profit-trading subsidiary; yes is outside_this_sheet. corporate_situation is standalone, group_member_or_holding, merger_or_division or missing. assessment_scope is individual_standalone or outside_sheet.
The sheet does not process group aggregates. A group member or a merger or division stays waiting_outside_sheet_scope. packaging_counted_once is yes, no or missing. no or missing is unresolved double counting and keeps producer_class waiting.
turnover_gbp and packaging_tonnes_nearest are numbers or missing. Tonnes are UK eligible packaging supplied in the reference year, rounded to the nearest tonne, counted once even if several producer classes apply.
producer_class, only when year alignment matches regulation 24, established in the UK is yes, producer activity is a named relevant activity, charity exemption is no, corporate situation is standalone, assessment scope is individual standalone, packaging counted once is yes, and turnover and tonnes are filled: large if turnover is more than 2,000,000 and tonnes are more than 50; small if turnover is more than 1,000,000 and tonnes are more than 25 and the row is not large; otherwise not_small_or_large_producer. Exactly 25 tonnes is not more than 25. Exactly 50 tonnes is not more than 50. Exactly £1 million is not more than £1 million. Exactly £2 million is not more than £2 million. Do not use the GOV.UK from-£1-million or from-25-tonnes table as the CSV rule. not_small_or_large_producer is not a finding that no packaging duty exists. row_status is waiting, recorded or outside_sheet. There is no registered, reported, fee_paid or lawful value.
Small producer next steps stay on GOV.UK
Small producers follow GOV.UK small-producer guidance and register the organisation through the Report packaging data service. They do not pay waste disposal fees or buy PRNs on that 19 February 2026 page. Reporting uses SP and HDC codes on that service. This page does not generate those files. Fees are not copied because official pages print different amounts. Do not use a large-producer-only registration procedure. Plastic Packaging Tax remains a separate HMRC 10-tonne test.
Save a copy of the blank file and type into the copy. The files are plain CSV with no formulas.
- Blank worksheet, epr-applicability-blank.csv
- Fictional boundary examples, epr-applicability-example.csv
Worked examples: missing tonnes and exact boundaries
Northgate Studio is fictional. Obligation year 2026, packaging reference year 2024, statutory accounts cutoff 7 April 2025, assessment date 1 October 2025, fictional financial year ending 31 March 2025 as the latest year ending before that cutoff for which accounts are available under regulation 24(5), year alignment matches regulation 24, established in the UK, selling filled packaging, standalone. Recorded is not a regulator decision. No fee is shown.
| Row | Inputs | Class |
|---|---|---|
| Missing tonnes | Turnover filled. Tonnes blank | waiting |
| Exact 25 tonnes | 25 tonnes, £1,500,000 | not_small_or_large_producer |
| Exact £1 million | 26 tonnes, £1,000,000 | not_small_or_large_producer |
| Exact £2 million | 51 tonnes, £2,000,000 | small |
| Above both large tests | 51 tonnes, £2,000,001 | large |
| Not established in the UK | Established in UK no | outside_this_sheet |
| Group member | Group situation. The sheet does not process group aggregates | waiting_outside_sheet_scope |
| No packaging activity | none |
outside_this_sheet |
| Unverified activity | Turnover and tonnes filled | waiting |
| Charity exemption | Charity supplying packaging, not a profit-trading subsidiary | outside_this_sheet |
| Double counting unresolved | Packaging counted once blank | waiting |
| Accounts available after the cutoff | Year ended 31 March 2025. Accounts delivered 30 June 2025. Assessment 1 October 2025. 40 tonnes, £1,500,000 | small |
| Unknown availability | Accounts available blank. 40 tonnes, £1,500,000 | waiting |
What this page does not finish
Plastic component weight for the tax stays on the tax guide. Disposal routes stay on the packaging component sheet. Official Report packaging data templates stay on GOV.UK. This worksheet is not that return and does not include a packaging-weight spreadsheet.
Your next action
Finish a standalone applicability row using named years and strict greater-than tests, leave group and merger cases outside the sheet, and never treat the class as a registered producer.
keep Plastic Packaging Tax as a separate HMRC 10-tonne test