Introduction
Extended Producer Responsibility is one of the most significant regulatory changes to affect the food manufacturing sector in recent years. While EPR applies to all industries that place packaging on the UK market, food manufacturers face a particularly complex set of challenges. This is due to the sheer volume of packaging used, the diversity of packaging formats, the need for strict food safety measures and the rapid pace of product and packaging updates.
The introduction of EPR means that manufacturers are now financially responsible for the management and recycling of the packaging they place on the market. It also creates new expectations in terms of data accuracy, packaging design and operational workflows. As a result, food manufacturers must rethink how they collect packaging information, how they collaborate internally, and how they use digital tools to maintain compliance.
This article explores the four most important aspects of EPR for food manufacturers. It breaks down the operational, financial and technical impacts, and offers clear guidance on what organisations need to do to stay compliant. It also explains how 4Pack helps food brands centralise their packaging data, streamline artwork processes and simplify reporting.
What EPR Means for Food Manufacturers
EPR requires producers to report detailed packaging information and pay fees based on the environmental impact of their materials. Producers must now track every component, weight and material used in their packaging, alongside providing evidence of recyclability and including correct recycling labels.
Food manufacturers are heavily affected because they tend to use a variety of packaging formats, each with its own material composition. For example, a single product may include a plastic tray, a film lid, a cardboard sleeve, a label and various internal layers to protect freshness. Each of these items must be reported accurately, with data provided for each component.
Why the Food Sector Faces Unique Pressures Under EPR
The food sector cannot simply remove parts of its packaging to meet EPR goals. Packaging must still protect the product, extend shelf life and meet safety regulations. Many food producers rely on barrier films, complex laminates or multi-layer plastics that are not yet widely recyclable. This means that EPR fees may be higher for these products, adding to operational and financial pressure.
Additionally, the food sector experiences constant product and packaging changes. New recipes, seasonal lines, promotional packs and variations for different retailers all require new packaging designs. Under EPR, each change must be tracked and reported, making packaging data management more complicated and time sensitive.
4 Things To Note Regarding EPR For Food Manufacturers
1. Packaging Material Obligations and Reporting Requirements
EPR introduces strict requirements around the reporting of packaging data. Food manufacturers must document each packaging item in detail, ensuring every material is correctly recorded and every weight is accurate.
EPR divides packaging into several categories based on its role within the supply chain. Food manufacturers must understand each category to ensure accurate reporting.
Primary Packaging
Primary packaging is in direct contact with food. It plays a vital role in preventing contamination, preserving freshness and extending shelf life. This includes:
- vacuum-sealed packaging
- trays and lids
- pouches and sachets
- bottles, jars and caps
- wrappers and films
Primary packaging often uses composite materials or laminates to maintain product quality. These materials are difficult to recycle and must be reported accurately.
Secondary and Tertiary Packaging
Secondary packaging helps group or display products. These items include:
- cardboard sleeves
- display boxes
- multipack trays
- shrink wrap
Tertiary packaging is used in distribution and shipping, such as:
- stretch wrap on pallets
- corrugated boxes
- outer cartons
- interleaving sheets
Even though these materials may not reach consumers directly, manufacturers must still report them.
Correct labelling is essential. In the UK, most food manufacturers follow OPRL (On-Pack Recycling Label) guidelines, which set out clear rules for communicating recycling instructions. EPR strengthens the need for labels to reflect accurate recyclability claims. Incorrect labels can lead to compliance issues and higher fees.
Mandatory Reporting Data: What Food Manufacturers Must Capture
Food manufacturers need robust systems to collect the following data:
- material type for every component
- exact weight of each component
- recyclability classification
- packaging format and structure
- where in the supply chain the packaging becomes waste
- packaging volumes placed on the market
Because food companies often manage hundreds or thousands of SKUs, capturing this data manually becomes unmanageable. Errors can lead to costly penalties, enforcement action or incorrect fee calculations.
Financial Implications of EPR Packaging Fees
Fees under EPR are modulated, meaning the cost depends on how easy the packaging is to recycle. For food manufacturers that rely on complex plastic films, mixed-material laminates and specialised barrier layers, fees can be significantly higher. As recycling infrastructure improves and modulated fees become more precise, this cost pressure will increase.
Manufacturers that invest in sustainable packaging design can reduce long-term fees, but redesigning packaging also takes time and resources. Balancing cost, performance and recyclability is therefore a major challenge under EPR.
2. Supply Chain Transparency and Data Accuracy
Accurate packaging data depends on clear supply chain communication. Food manufacturers often work with a mixture of packaging suppliers, ingredient suppliers, co-packers, printers and third-party logistics partners. This creates several challenges.
EPR requires end-to-end traceability. Manufacturers must be able to show:
- where each material came from
- what coatings or barriers were applied
- how different materials are layered
- which supplier provided which component
- how the final packaging was assembled
This traceability supports both compliance and quality assurance. Without detailed records, companies can struggle to provide accurate reporting or verify claims from suppliers.
Many suppliers do not provide packaging data in a consistent format. Specifications may be delivered as PDFs, spreadsheets, emails or drawings. Some may lack detail or use different terminology for the same material type. Food manufacturers must consolidate all this information and ensure that it remains up to date.
Certain materials, such as multilayer films, can be particularly difficult to document. Each layer must be recorded separately, and recyclability depends on the full structure, not just the dominant material.
Common Data Challenges for Food Manufacturers
Complex Packaging Formats
Food packaging often includes multi-material laminates, oxygen barriers, resealable zips and coated papers. Breaking these down into reportable data points requires a high level of technical understanding and structured data capture.
Frequent Packaging Updates
Packaging can change due to recipe changes, new allergen information, retailer requirements or sustainability improvements. Under EPR, every update must be accurately reflected in the data. Without strong version control, errors are likely.
Global Supply Chain Variations
For multinational food manufacturers, packaging data can differ between markets. Recyclability labels may vary, and packaging structures may not be identical across countries. This increases the need for centralised data management.
3. Packaging Design, Sustainability Targets and Material Choices
EPR is accelerating the shift towards sustainable packaging. Food manufacturers must now consider recyclability as a core design principle.
Recyclability is increasingly influencing packaging design decisions. Manufacturers are under pressure to:
- remove unnecessary components
- reduce the number of materials in each pack
- switch to mono-material structures
- phase out non-recyclable plastics
- choose packaging that is compatible with UK recycling systems
This requires collaboration between packaging developers, designers, technical teams and sustainability leads.
Minimising Waste and Improving Recyclability
Improving recyclability involves decisions such as:
- replacing PVC or PS with PET
- switching from laminated film to recyclable mono-material films
- eliminating metallic layers or carbon black plastics
- using board with water-based coatings rather than plastic laminates
On-pack recycling instructions must reflect the actual recyclability of the packaging. Incorrectly marked packaging can mislead consumers and breach EPR rules.
Impact on Cost, Procurement and Product Development
While sustainable packaging innovations are improving, recyclable alternatives are sometimes more expensive. Procurement teams must weigh the higher cost of recyclable materials against the long-term reduction in EPR fees.
Product development teams also need to test new packaging structures. Recyclable materials may behave differently in sealing, filling or printing machines. They may also interact differently with the food, affecting freshness, durability or appearance.
The highest priority in food manufacturing will always be safety and quality. Some recyclable materials may not provide the moisture, oxygen or light barriers needed for safe food packaging. Manufacturers must therefore find the right balance between recyclable design and functional protection. This often involves running trials, testing new materials and working closely with suppliers.
4. Operational and Organisational Readiness
EPR is not just a packaging challenge. It is an operational challenge that affects every stage of the packaging lifecycle.
EPR requires strong collaboration between:
- packaging development
- technical and quality teams
- artwork and regulatory teams
- procurement
- sustainability teams
- marketing
- operations
- suppliers
Without clear workflows, version control and data ownership, packaging information becomes inconsistent. EPR demands a structured approach to updates, approvals and record keeping.
The Growing Role of Digital Systems in EPR Compliance
Digital systems are now essential for EPR management. They:
- centralise packaging data
- store specifications in one place
- automate version tracking
- manage artwork approvals
- prevent outdated files being used
- generate accurate reports
- improve team collaboration
Without digital tools, manual processes quickly become unmanageable.
Training Teams and Embedding Compliance Into Daily Operations
EPR compliance is an ongoing responsibility. Staff must understand:
- which data needs to be collected
- how changes affect reporting
- where data should be stored
- how to avoid outdated information
- why accuracy is essential
Regular training and clear internal policies ensure that compliance becomes part of daily operations.
How 4Pack Supports EPR Compliance for Food Manufacturers
4Pack is designed to support the precise data and artwork needs of food manufacturers. It brings packaging teams, suppliers and technical departments together in one digital platform.
Centralised Packaging Specification and Artwork Control
With 4Pack, all artwork files, packaging specifications and material details are stored in a central location. This ensures:
- complete version control
- consistent packaging information across all teams
- accurate specifications linked directly to artworks
- fewer errors and less duplication
- faster approvals
This single source of truth is vital for EPR reporting.
Automated Data Capture, Versioning and Reporting
4Pack automates key compliance tasks such as:
- approval workflows
- version tracking
- data updates
- audit trails
- report exports
This automation reduces the risk of manual errors and ensures the latest information is always available.
The platform gives all stakeholders a shared workspace. Teams can review, annotate and approve documents directly within the system. This removes confusion caused by email threads, disconnected spreadsheets or outdated files.
Reducing Errors and Ensuring Regulatory Consistency
4Pack ensures that:
- recycling labels are accurate
- mandatory legal text is always present
- specifications meet the latest EPR rules
- artwork updates are fully tracked
- regulatory information is applied consistently across all SKUs
This reduces compliance risks and gives organisations confidence in their packaging accuracy.
Book a Demo to See 4Pack in Action
To understand how 4Pack can transform your packaging operations and help you stay compliant under EPR, book a demo with our team. We will show you how the platform manages data, streamlines workflows and supports every part of the packaging lifecycle.
Future Outlook: How EPR Will Evolve for the Food Sector
EPR will continue to develop over the next decade. Food manufacturers must stay informed to avoid future risks.
Potential Fee Changes and Modulated Fees
As recycling technologies advance, fees are likely to become more targeted. Packaging that is fully recyclable will be rewarded with lower fees, while complex materials may be penalised. Food manufacturers need to continue innovating to reduce long-term costs.
Consumers increasingly expect brands to offer environmentally responsible packaging. Clear recycling labels, simpler materials and visible sustainability commitments all affect brand perception. EPR reinforces these expectations and makes transparency essential.
The Increasing Need for Real-Time Packaging Data
EPR reporting will grow more data-intensive. Manufacturers will need real time access to packaging information to meet reporting deadlines and respond to retailer audits. Digital systems will become even more important.
Takeaway
EPR represents a major shift for food manufacturers. It requires accurate data, sustainable packaging design and strong operational processes. By understanding the impact of EPR and preparing early, manufacturers can reduce fees, improve accuracy and maintain compliance.
4Pack offers a powerful solution for managing packaging data, artwork files and compliance workflows. With a single source of truth, automated processes and strong collaboration tools, food manufacturers can stay ahead of regulatory changes and focus on delivering safe, high quality products.
