Packaging EPR for a small online shop: the 25-tonne and £1 million tests, how many parcels that is, and what a small producer must report

A seller packing orders in a spare room does not expect a packaging regulation to apply. For nearly every small online shop it does not, but the rule is written in tonnes, so owners rarely know how far off they are. This guide turns the test into parcels.

The two tests

The GOV.UK guidance on extended producer responsibility (EPR) for packaging says a business is obligated if both of these were true in the previous year:

• "you supplied or imported more than 25 tonnes of packaging in the UK", and
• "your annual turnover worldwide was £1 million or more".

Miss either one and there is no obligation. The guidance table is plain: under 25 tonnes of packaging, no obligation at any turnover, and turnover of £1 million or less, no obligation at any packaging weight.

Between the two lines sits the small producer: 25 to 50 tonnes with turnover over £1 million, or more than 50 tonnes with turnover between £1 million and £2 million. A large producer needs more than 50 tonnes and more than £2 million turnover.

What counts as packaging

GOV.UK describes packaging as items used to "contain, protect, handle, deliver or present goods supplied to an end user". That covers the shipping box, the padded mailer, the tape, the void-fill and the product's own box. It includes online marketplace sellers who supply packaging, filled or unfilled, from outside the UK into it.

Weigh everything that goes to the customer or comes with the goods. The guidance asks for the packaging of the year before, so for the 2026 reporting cycle it points to 1 January to 31 December 2025, and to turnover figures from accounts available before 7 April 2026.

What that is in parcels

This is where the numbers reassure most shops.

A shop sending 30 parcels a day at 150 g uses 30 × 365 × 150 g = 1,642,500 g, or about 1.6 tonnes. That is 6.6% of the line. A busy shop at 200 parcels a day at 300 g uses 21.9 tonnes, which is still under 25.

The turnover test also has to be met

Packaging weight alone does not make a shop obligated. At 150 g a parcel, a shop that reaches 25 tonnes has shipped 166,667 parcels. For turnover to reach £1 million as well, average sales per parcel must be £6.00 or more. A shop selling stickers at £3 a parcel could pass the weight line without meeting the turnover line. A shop selling furniture at £250 a parcel would cross £1 million at 4,000 parcels, nowhere near 25 tonnes unless each parcel is very heavy in packaging.

For most small sellers the sensible conclusion is the one in the table above: no obligation. Write the calculation down once a year, with the packaging weight per parcel and the parcel count, so there is a record of why.

If you are a small producer

The GOV.UK guidance says small producers must register annually with the environmental regulators, report packaging data every year and keep the data for seven years. It says small producers pay no recycling fees, unlike large producers, who must buy recycling notes and pay waste disposal fees.

How this fits with other thresholds

A shop that watches its turnover line for VAT registration already has the sales figure this test needs. Packaging weight is the part most owners have not measured. The marketplace fee calculator shows the margin on each order, and packaging cost per parcel is a line worth adding to it. The product safety checklist is the other rulebook that asks you to know what goes in the box.

Where Overlyft fits

Overlyft can set up an AI assistant for online shops that takes the order export, multiplies it by the packaging weight the owner has measured for each parcel size, and produces the yearly packaging-tonnage note and the turnover check for the owner to read and file. It does not register a business, decide whether a shop is obligated or submit reports to the regulators.

This is general information for the UK and not legal advice. Check the current GOV.UK guidance before relying on a threshold.