Air Quality
Packaging Compliance: A Growing Business Risk
31st May 2026
NetRegs has asked Arthian to provide an insights article exploring the growing compliance risks associated with packaging regulations across the UK and how SMEs can respond to this.
As UK environmental regulators SEPA and NIEA’s NetRegs online guidance states, you must comply with packaging regulations if your business manufactures, fills, supplies/imports or handles packaging or packaging materials. Every organisation handling packaging should be aware of these regulations and how these may apply.
There are specific thresholds which apply to obligated UK organisations – two key thresholds for obligations to apply are:
- importing or supplying more than 25 tonnes of packaging to the UK market in the previous calendar year, and
- £1million minimum turnover.
You may need to collect and report packaging data, and there are financial implications to be met. For those above the thresholds, this blog brings insights into understanding and managing packaging compliance obligations.
Why Packaging Compliance Matters
For many organisations, packaging has historically been viewed simply as something used to protect products during storage and transport. Extended Producer Responsibility (EPR) for packaging and Plastic Packaging Tax (PPT) obligations are increasing the level of scrutiny placed on packaging data, and packaging is now becoming an area of growing regulatory, financial, and reputational risk if responsibilities are not fully understood. Packaging compliance has often received less attention than other areas of environmental compliance, with many organisations previously managing obligations through existing producer responsibility arrangements without significant data or reporting structures.
Arthian are finding that organisations are also finding the transition from previous producer responsibility requirements towards wider Extended Producer Responsibility (EPR) requirements challenging due to increased reporting expectations, data requirements, and the need for greater accuracy in packaging information.
Understanding Who Has Obligations
In practice, we are seeing many businesses underestimate the complexity of packaging obligations, particularly where imported goods, online sales, or multiple supply chain roles are involved.
Organisations are often surprised to learn that obligations may apply not only to manufacturers, but also to importers, distributors, online retailers, and businesses supplying products under their own brand. In some cases, businesses may undertake several packaging activities across their operations without realising this can create multiple reporting responsibilities.
Organisations may also inadvertently hold obligations under both Extended Producer Responsibility (EPR) or Plastic Packaging Tax (PPT) requirements without fully understanding how the rules apply to their operations.
The Data Challenge
One of the biggest challenges organisations face is obtaining accurate packaging data in the first place. Across a range of sectors, businesses are often struggling to:
- Obtain packaging specifications from suppliers;
- Identify all packaging materials types and weights;
- Separate UK and export packaging flows;
- Understand the different between household and non-household packaging; and
- Determine which packaging activities are reportable, and when.
This can become particularly challenging where packaging is sourced internationally, specifications frequently change, or packaging data has never historically been collected.
For some organisations, even understanding where packaging enters and leaves the business can be a significant exercise. Businesses with multiple sites, imported products, contract manufacturing arrangements, or online sales channels may find that packaging responsibilities are spread across several departments with no clear ownership of the data.
Practical First Steps
Businesses do not need to have perfect systems in place overnight, however organisations that begin reviewing their packaging data early and getting appropriate management systems in place are generally finding the process significantly easier than those reacting closer to reporting deadlines.
Practical first steps may include:
- Mapping packaging flows into and out of the business;
- Identifying who internally is responsible for packaging data;
- Engaging suppliers to request packaging information;
- Reviewing import and distribution arrangements,
- Improving internal record keeping processes, and
- Building the packaging compliance process into their environmental management system.
The Value of Compliance Reviews
For some organisations, obtaining specialist support can also help simplify the process. Whilst packaging reporting itself is often managed through compliance schemes, businesses may benefit from independent reviews from consultancies such as Arthian to better understand how the regulations apply to their operations, identify compliance gaps, review existing data collection processes, and prepare for future obligations.
Arthian are increasingly seeing organisations use environment legal compliance audits and packaging reviews as a starting point to understand their responsibilities and prioritise improvements before reporting deadlines. This can be particularly valuable for businesses operating across complex supply chains or where packaging responsibilities have developed over time without formal review.
The Future
Packaging requirements will continue to evolve, with increasing focus not only on reporting obligations, but also on wider sustainability considerations such as recyclability, recycled content, material choices including reducing/ avoiding single use virgin plastics, and clearer packaging labels.
As regulatory scrutiny and customer expectations continue to grow, businesses may need to place greater focus on understanding the packaging they place on the market, maintaining accurate data, and keeping up to date with changing legislation and compliance requirements.
Arthian support includes:
- Environmental legal registers
- Identifying legislation applicable to your operations
- Quarterly legislation updates
- Annual environmental legal compliance audits
- Specific packaging compliance support
Contact EHS Compliance Lead Jill Cottrell at jill.cottrell@arthian.com for more information.
This article was written at the invitation of NetRegs — environmental guidance for businesses in Northern Ireland and Scotland, a partnership of the Northern Ireland Environment Agency (NIEA) and of the Scottish Environment Protection Agency (SEPA).
