What changed on 19 August 2026?
The new GOV.UK guidance explains how organisations that need to register directly with their environmental regulator should prepare and submit their registration information through the Report Packaging Data service.
It includes downloadable CSV templates and detailed field-by-field instructions covering areas such as:
- organisation details;
- annual turnover;
- packaging activities;
- contact information;
- approved or delegated persons;
- brand details;
- partnership information;
- organisation size;
- updates to previously submitted registration details.
The government also updated its wider EPR compliance guidance on the same date to improve clarity around which packaging activities can make an organisation an obligated producer.
For businesses selling custom T-shirts, hoodies, workwear or branded merchandise online, this is a useful reminder that EPR is not only an issue for packaging manufacturers. Retailers and brand owners can also become responsible depending on how they supply, import, pack or sell packaged goods.
What is packaging EPR?
Extended Producer Responsibility is designed to shift more of the cost and responsibility for packaging waste onto the organisations that place packaging on the UK market.
Under current GOV.UK guidance, businesses should check whether they carry out activities such as:
- supplying filled packaging under their own brand;
- packing goods into packaging;
- importing packaged goods into the UK;
- supplying empty packaging;
- hiring or loaning reusable packaging;
- operating an online marketplace that allows non-UK organisations to sell packaged goods into the UK;
- selling filled packaging to an end user.
For an apparel business, the relevant packaging might include shipping boxes, mailer bags, product sleeves, branded boxes or other material used to contain, protect, handle, deliver or present goods.
The precise responsibility depends on the supply chain and activity, so businesses should use the official GOV.UK guidance rather than assuming responsibility automatically falls on the company that physically posts the parcel.
What are the current EPR thresholds?
The government says a UK-established organisation is an obligated producer if it carries out a relevant packaging activity and, in the previous year, it:
- supplied or imported more than 25 tonnes of packaging in the UK; and
- had worldwide annual turnover of £1 million or more.
Those thresholds then determine whether an obligated organisation is treated as a small or large producer.
For 2026 reporting, GOV.UK says businesses should assess packaging supplied or imported between 1 January and 31 December 2025, and use the relevant annual-turnover figure from the latest accounts available before 7 April 2026.
The current threshold table broadly means:
- below 25 tonnes of packaging: no EPR obligation under the stated threshold test;
- 25–50 tonnes with turnover above £1 million: generally a small producer;
- more than 50 tonnes with turnover above £2 million: generally a large producer;
- businesses with turnover of £1 million or less fall outside the obligation under the current threshold table.
This is one reason many small custom-clothing businesses will not immediately fall into the scheme. But a fast-growing ecommerce brand can reach significant packaging volumes surprisingly quickly, especially when fulfilment includes boxes, mailers, inserts and imported packaged stock.
Why this matters to custom clothing brands
A clothing business can think of its packaging as a relatively small part of each order. Across thousands of orders, however, the total volume becomes much more significant.
A typical ecommerce order might involve:
- an individual garment bag or product wrapper;
- a mailing bag or cardboard shipping box;
- tissue paper;
- protective material;
- branded product packaging;
- labels or other packaging components.
Which items count, who is responsible for them and how they should be reported depends on the rules and the business’s role in the supply chain.
That makes packaging data increasingly important as a business grows. Waiting until the company is already close to the threshold can make historic data difficult to reconstruct.
Own-brand packaging is specifically covered
The new registration guidance asks organisations to identify whether they supply goods in the UK in packaging under their own brand.
GOV.UK also makes clear that an organisation can remain a producer in some situations even when another business physically imports, packs or manufactures goods that are later sold in the brand owner’s branded packaging.
This is particularly relevant to clothing brands using contract manufacturers, fulfilment centres or third-party packers.
Outsourcing part of the operation does not necessarily mean the packaging responsibility disappears. Businesses need to understand who performs each obligated activity and how the regulations allocate responsibility.
Ecommerce sellers should pay attention to fulfilment packaging
For an online clothing business, the parcel arriving at the customer’s home is part of the product experience — but it is also part of the packaging flow that may need to be tracked.
This creates a practical tension. Premium packaging can improve presentation, but unnecessary layers increase material consumption, shipping weight and potentially the amount of packaging a business needs to account for.
As EPR becomes more established, growing ecommerce brands have another reason to review whether every packaging component is genuinely useful.
Reducing unnecessary packaging can potentially lower material costs, simplify fulfilment and reduce packaging tonnage at the same time.
What information does the new registration process require?
The 19 August guidance says organisations registering directly need to provide information including their address, annual turnover, packaging activities and relevant contacts.
Businesses may also need to provide brand information when they supply goods in UK packaging under their own brand.
The government has published CSV templates for organisation details, brand details and partnership details. It warns businesses not to remove columns from the templates even when some fields do not apply, because the files need to follow the required structure.
The guidance is highly specific about formatting. For example, organisations must use the prescribed values and capitalisation for coded fields, and some characters can trigger validation errors.
For larger organisations with complex structures, this makes EPR registration a data-management exercise rather than simply a one-page form.
Businesses must keep registration details updated
The new guidance also states that submitted information needs to remain current.
Changes generally need to be reported within 28 days by submitting updated registration details to the environmental regulator. Examples include changes to contact information, registered addresses or group subsidiaries.
That means packaging compliance cannot simply be completed once and forgotten. Growing brands need an internal process for keeping organisational and packaging records accurate.
Does this mean every small clothing business has to register?
No.
The threshold test matters. A microbusiness selling small numbers of personalised T-shirts is unlikely to handle tens of tonnes of packaging in a year.
But businesses should not confuse employee headcount with EPR status. The official definition of a small producer is based on turnover and packaging tonnage rather than how many staff the organisation employs.
A business can therefore remain operationally small while still becoming obligated if its sales and packaging volumes grow enough.
What should growing ecommerce brands do now?
Even businesses below the current thresholds can use the update as an opportunity to improve packaging records.
A sensible approach is to understand which packaging materials enter and leave the business, who supplies them, how much is used per order and which organisation in the supply chain is responsible for the relevant activity.
Growing brands may also want to:
- Track packaging purchases by material and weight. Supplier specifications can make later calculations easier.
- Separate product packaging from fulfilment packaging. This helps clarify where packaging enters the customer journey.
- Document imported packaged goods. Imported products can create different responsibilities from UK-sourced stock.
- Review unnecessary packaging layers. Removing waste can reduce both cost and material volume.
- Check official guidance as turnover grows. Crossing a threshold can change reporting requirements.
- Avoid relying on informal online summaries alone. EPR rules are technical and official guidance should be the primary reference.
What this means for custom printing and merchandise
The broader custom-merchandise market is moving toward smaller production runs and on-demand ordering, which can reduce unsold garment inventory. Packaging is the next part of that workflow businesses increasingly need to optimise.
A made-to-order T-shirt avoids producing stock before it sells, but it still needs to reach the customer safely. The opportunity is therefore to pair flexible production with efficient packaging: enough material to protect the product, but not more than necessary.
For print businesses serving clothing brands, events and creators, packaging questions may also become part of the customer conversation — especially when fulfilment is included as a service.
Is this a new tax on small clothing brands?
It is more accurate to describe EPR as a regulatory producer-responsibility system rather than a blanket tax on every clothing business.
Whether a company has obligations depends on the activities it performs, its annual turnover and the amount of packaging it supplies or imports. Large and small producers also have different requirements.
Businesses should therefore avoid assuming they are either automatically included or automatically exempt.
The important SEO and market signal
Search interest around terms such as EPR packaging UK, packaging compliance, ecommerce packaging rules and producer responsibility is becoming more commercially relevant as UK businesses move from general awareness to practical compliance.
For apparel and merchandise sellers, there is comparatively less useful content explaining the rules through the lens of clothing fulfilment. That creates a useful long-tail information gap: businesses want to understand what government packaging rules actually mean for everyday ecommerce operations.
The bottom line
The government’s new 19 August 2026 registration guidance does not suddenly bring every T-shirt printer or clothing brand into packaging EPR. What it does is make the registration process more explicit for businesses that already meet the relevant criteria.
For growing custom-clothing and ecommerce brands, the practical lesson is simple: start understanding your packaging before compliance becomes urgent.
Knowing how much packaging the business uses, where it comes from and who is responsible for it can make future reporting easier — while also exposing opportunities to cut waste and fulfilment costs.
Businesses that may be close to the thresholds should check the latest GOV.UK guidance or take appropriate professional compliance advice for their specific circumstances.
