In this exclusive blog for Products of Change, POC Member, Just Good, takes us through navigating the UK Extended Producer Responsibility Legislation (EPR) and how to mitigate unexpected costs.
By Amy Briggs, head of marketing, Justgood.
Have the recent EPR funding shortfall headlines caused a mild panic for finance and a strong coffee dependency in your procurement team? Then just know, you’re not alone.
Here’s the uncomfortable truth: Packaging can no longer be a design afterthought. It is a regulated cost centre, ready to bite you if you continue treating it as such. Under UK Extended Producer Responsibility (EPR), packaging choices don’t just affect shelf appeal and transit damage. They affect your compliance exposure, reporting burden, and future invoices.
EPR has entered the chat (and it brought a calculator)
UK packaging EPR shifts the cost of dealing with packaging waste from councils to the businesses that create it.
If you put packaged goods on the UK market, you now help fund what happens to that packaging at end of life. That brings: more reporting, more data requirements, more scrutiny, and fees linked directly to material choices
Recent industry coverage has highlighted funding gaps and shortfalls, with fee assumptions shifting upward. It’s a timely reminder that packaging cost models built on guesswork don’t age well.
Not just a grocery problem. An everyone problem.
EPR applies to all consumer packaging, not just supermarket food packaging.
That includes:
- Retail products
- Contract-manufactured goods
- Promotional merchandise
- Event kits and welcome packs
- E-commerce packaging
- Branded resale products
If it’s packaged and placed on the UK market, it’s in scope.
The good old days, when your biggest worry was packaging that fit
The old workflow used to be to sort the product first, then the packaging. This is now financially a dangerous game.
EPR fees depend on material type, recyclability reality, weight, composite formats, and separation difficulty. Two similar-looking packs can generate very different compliance costs.
“Looks sustainable” is not a strategy
EPR is based on material facts, not appearances. You need verified specs, recycled content evidence, chain-of-custody paperwork, recyclability pathways, and supplier audit trails.
If suppliers can’t prove it, you carry the risk. Because it isn’t who made the product, it’s who brought it to the UK market first.
How to avoid the EPR sting
Start with the end in mind. Choose materials based on end-of-life care. Simplify packaging structures. Model EPR compliance cost early. Align procurement, sustainability, and commercial teams before decisions are locked. This is critical because typically, these teams work in siloes.
Packaging is now a financial lever, so start earlier
Good packaging strategy reduces compliance risk, controls fee exposure, supports credible sustainability claims, avoids redesigns, and protects margin. Working with the right supplier is crucial. It means that not only do they produce the packaging, but they also help build this into a meaningful business case.
Designing it right from the start, providing proof, and modelling the impact for you, early is vital. The risk of leaving packaging until the end of development exposes you to unnecessary EPR risk and cost. If you don’t know where to start or how to get your business to think differently, find a good supplier to support you.
About Justgood
Justgood manufacture and source sustainable retail products for brands to be proud of, helping buyers protect margins, marketers tell compelling stories, and sustainability managers move products into the circular economy without the headache.
They work with clients to get ahead of EPR requirements by bringing packaging design much earlier into the process. Taking a cradle-to-cradle approach, Justgood help teams across the value chain understand how packaging and material decisions affect compliance, cost, and circularity before those decisions become expensive to change.
