Under the UK’s new Extended Producer Responsibility [EPR] rules, some private-label and contract food manufacturers may face unexpected costs.
EPR shifts full responsibility for the life cycles of packaging onto producers, meaning any business whose brand, logo or mark appears on packaging could be liable for reporting and recycling fees even if they manufacture products for a supermarket or another “own-brander.”
The first EPR invoices are being issued in October 2025, with labelling obligations from April 2027. The rules’ broad drafting means that the first brand on packaging may carry financial responsibility, catching out many suppliers who assumed retailers would bear the cost.
Action point: Businesses should review packaging designs and contracts with retailers now to clarify who carries EPR liability and adjust branding or terms where possible. Seek specialist advice if uncertain.
Protect Public Health - Ensure Safe Production - Maintain Trusted Quality
Hidden Costs for Food Producers
New EPR Rules: Hidden Costs for Food Producers
Under the UK’s new Extended Producer Responsibility [EPR] rules, some private-label and contract food manufacturers may face unexpected costs.
EPR shifts full responsibility for the life cycles of packaging onto producers, meaning any business whose brand, logo or mark appears on packaging could be liable for reporting and recycling fees even if they manufacture products for a supermarket or another “own-brander.”
The first EPR invoices are being issued in October 2025, with labelling obligations from April 2027. The rules’ broad drafting means that the first brand on packaging may carry financial responsibility, catching out many suppliers who assumed retailers would bear the cost.
Action point: Businesses should review packaging designs and contracts with retailers now to clarify who carries EPR liability and adjust branding or terms where possible. Seek specialist advice if uncertain.
Protect Public Health - Ensure Safe Production - Maintain Trusted Quality