From 1 January 2026, the UK’s packaging extended producer responsibility (EPR) regime changes under the Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025. The instrument applies across England, Scotland, Wales and Northern Ireland and updates the 2024 Regulations on definitions, reporting, fee setting and scheme delivery.
A new ‘closed loop’ offset is introduced for food‑grade plastic packaging that the same producer collects directly from consumers and sends to a single accredited reprocessor to be recycled back into food‑grade material. Large producers must pay an additional annual charge of £2,548 to use the offset and report by the set deadlines: data for January–June 2024 and July–December 2024 by 28 January 2026, and January–June 2025 by April 2026. Producers cannot submit closed‑loop data unless the charge is paid.
Material categories are refined. ‘Fibre‑based composite material’ is now defined as packaging made of paperboard or paper fibres with one or more plastic layers forming a single unit not separable by hand; ‘paper or board’ includes such items where the plastic layer(s) are no more than 5% of mass, allowing certain laminates to be treated as paper/board for reporting and fees. The rules also align exemptions with deposit return schemes, excluding deposit items and lines covered by a ‘low volume line exemption’.
Producer roles are clarified. After the first supply of packaging, no new producer arises in the chain except a seller, unless a further component (for example a new label) is added-when obligations are determined for that new component. Where multiple brands appear, the brand owner that first supplies the filled packaging is the producer; otherwise the brand occupying the largest external surface is treated as the producer. New provisions also set out how obligations move in corporate events, including mergers and transfers of brands or businesses.
Reporting and evidence requirements are tightened. Producers must retain data and evidence for seven years, including proof that any household packaging waste reported as collected from consumers has actually been recycled. This evidential standard applies to any claims made in data returns and underpins fee calculations in subsequent assessment years.
Disposal fee policy is adjusted to better reflect environmental outcomes. In making assessments of relevant authority costs and in setting and modulating fees, the scheme will now explicitly take account of the environmental effects described in the EPR policy statement. This sits alongside the core objective that producers fund efficient local authority services for household packaging waste.
Governance changes enable the scheme administrator to appoint a Producer Responsibility Organisation (PRO)-a not‑for‑profit, producer‑led body-to carry out specified functions, subject to ministerial consent. The intent is to improve operational delivery while maintaining public accountability for policy and oversight.
Enforcement is strengthened against non‑compliant businesses. The scheme administrator gains powers to identify liable producers that failed to register or report (‘free riders’), calculate charges using best available estimates and add interest, removing any advantage over compliant firms.
Reprocessors and exporters face a new compliance framework from 2026: registration is mandatory (with accreditation remaining voluntary if PRNs/PERNs are to be issued), applications move to the regulators, and it becomes an offence to operate without registration after 1 January 2026. Determination can take up to 12 weeks, so early applications are advised.
What this means in practice for producers is immediate. Finance and compliance teams should decide early whether a food‑grade closed‑loop route is viable and, if so, organise evidence chains and the £2,548 payment in time for the January 2026 deadlines. Packaging technologists should review the new material definitions to confirm category reporting and fee exposure, and legal teams should map any mergers, acquisitions or brand transfers to the new notification and data‑resubmission duties so that obligations are correctly allocated for 2024–2026.