Why one buying entity does not produce one obligation

Buyers who serve Britain and Ireland from one desk usually built that desk before 2021, when the two markets sat inside the same regulatory perimeter.

That is no longer true, and the divergence is not cosmetic. Ireland is an EU member state, so Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, has applied there since 12 August 2026. England, Scotland and Wales are outside it: the Department of Agriculture, Environment and Rural Affairs records that a decision on whether to align with the PPWR across the UK has not been taken and that a consultation is planned. Northern Ireland sits in a third position, set out below.

The two national schemes were already built differently. The UK scheme is a statutory reporting obligation to a public regulator, with a compliance scheme as an optional intermediary. The Irish scheme is membership of an approved compliance scheme, with the statutory obligation discharged through it. Those are not the same shape, and they do not fail in the same way.

The two regimes on the same axes

The table compares the points that determine whether you are caught, who you deal with and when you file.

The UK: thresholds, activities and a six month rhythm

Three things have to be true before a UK obligation exists: annual turnover above £1 million, more than 25 tonnes of packaging supplied or imported in the UK, and a qualifying packaging activity. Miss any one and there is no obligation.

The packaging activities are the part buyers misread. Government guidance lists supplying under your brand, packing or filling, importing, supplying as empty, hiring or loaning reusable packaging, and supplying through an online marketplace. Importing is not the only route in.

If filled packaging carries your brand, you report it under “supplied under your brand”, including where you paid another organisation to import it for you. Where packaging displays more than one brand, the brand owner who is the first UK producer to supply the filled packaging reports it, and where none of them made the first supply, the owner of the brand occupying the largest area reports it.

One rule catches private label imports specifically. You must report branded packaging you packed or filled where the brand belongs to an organisation not established in the UK, or to a UK organisation that is not a large producer. A UK packer handling goods for a non-UK brand owner does not get to push the obligation offshore.

The reporting calendar is fixed and public.

Registration runs on the same dates: large producers register each year and pay the applicable fees by 1 October, small producers register and pay a registration fee by 1 April. Getting the data wrong is not free either. A resubmission of packaging data attracts a fee of £807 where you are registered directly with your environmental regulator, or £512 where you are registered through a compliance scheme.

Large producers also have to obtain packaging waste recycling notes, known as PRNs, or packaging waste export recycling notes, known as PERNs, to meet recycling obligations, and must report nation data where they sell filled packaging direct to an end user. Small producers currently collect and report data and pay a registration fee without the recycling note obligation. Confirm your own position with your regulator, because the phasing has moved.

Ireland: Repak membership is the mechanism, not an option

Ireland reaches the same policy outcome by a different route. A major producer places 10 tonnes or more of packaging on the Irish market annually and has annual turnover above €1 million. Before 2023 such a producer could self-comply under local authority oversight. The 2022 amendment to the European Union (Packaging) Regulations 2014, in operation from 1 January 2023, removed that and required membership of an approved body, on the stated basis that all producers should participate on a fair and equivalent basis.

Repak is that body: a not-for-profit owned by its members, operating under licence from the Department of Climate, Energy and Environment, with over 3,500 members. Fees are set against the volume of packaging a member places on the Irish market. Repak offers Regular membership for manufacturers, importers, brandholders, distributors and large retailers, and Scheduled membership for smaller businesses, growers and market gardeners, with separate application routes for distance sellers outside Ireland without an Irish VAT number.

Two Irish points belong in a 2026 plan. Repak states that businesses placing packaging on the Irish market are required under the PPWR to register with Repak and will be subject to the relevant EPR fee. And Repak will cease its licensor status for the Green Dot at the end of 2026, advising businesses to consider removing it at the next planned artwork update rather than paying for a separate redesign later. If your Irish cartons carry the Green Dot, that is an artwork decision with a print lead time, and it belongs in the same conversation as the French marking rules in CITEO registration and the Triman mark.

Repak also notes that harmonised EU packaging labels are expected from 12 August 2028, or 24 months after the relevant implementing acts enter into force, whichever is later. Plan artwork against the published timeline rather than against speculation about a delay.

Northern Ireland is neither of the above

Northern Ireland is where a single-desk assumption does the most damage, because the answer is genuinely split.

DAERA states that much of the PPWR applies in Northern Ireland under the Windsor Framework from 12 August 2026, and that a Commission Notice specifies the parts that do not. Applicable in Northern Ireland: recyclability of packaging, labelling, and restrictions on single-use packaging. Not applicable: re-use and refill targets, extended producer responsibility and deposit return scheme obligations, and recycling targets.

Read that carefully. The PPWR’s EPR machinery is carved out of Northern Ireland, so packaging producer responsibility there continues to run on the UK pEPR scheme with the Northern Ireland Environment Agency as regulator. The product rules are not carved out. A carton sold into Belfast can therefore be inside the EU regulation for what it is made of and how it is labelled, and inside the UK scheme for who pays for its disposal. That is a data question as much as a legal one, because UK nation level reporting has to distinguish it.

Which structure to run

The honest answer depends on where the volume is, and for some buyers the answer is to use somebody else’s registration.

One entity, both islands, if the entity is in Ireland and the UK volume is small. An Irish entity selling into Great Britain is measured against the UK turnover and tonnage tests. Below £1 million turnover or 25 tonnes there is no UK obligation at all.

Two entities if both markets carry real volume. Once the UK side is a large producer, the six month reporting rhythm, the recycling note obligation and the nation data requirement are a standing workload that does not share cleanly with an Irish membership filing.

Neither, if you are testing. Buying the first pallets from a British or Irish distributor who already holds the registration is slower on margin and faster on time to shelf. That trade off is set out in Indian manufacturer or European importer.

One flow to check with your broker: movements between EU member states are not imports for the purposes of the PPWR, but Great Britain is not an EU member state, so a shipment from a British warehouse into Ireland is not a member state to member state movement. Confirm how your flow is treated with your customs broker and with Repak before designing the route. The same packaging dataset serves both schemes, and it is set out in the supplier data you need before you can file an EPR return.

Frequently asked questions

Related reading

• You or your supplier: who registers for EPR when you import from India
• The supplier data you need before you can file an EPR return
• Packaging EPR in France: CITEO, the Triman mark and what goes on the pack
• Festival and outdoor catering supply in the UK and Ireland

References