The Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025 have been approved and take effect on 1 January 2026 across the UK. The instrument was laid on 3 November 2025 following four‑nation engagement under the Environment Act 2021. Practitioners should assume the new rules apply to activity and reporting from the first 2026 period unless transitional provisions state otherwise.
Technical definitions are tightened. ‘Fibre‑based composite material’ is clarified and a new interpretation of ‘paper or board’ is introduced: where a fibre‑based pack contains plastic layers not exceeding 5% of the material by mass, it may be treated as paper or board. Deposits interaction is also updated so items that are, or would be, deposit‑scheme ‘deposit items’ (subject to any low‑volume line exemption) are excluded. These adjustments affect material categorisation, fee bands and reporting.
A new closed‑loop route allows large producers to offset certain food‑grade plastic household packaging they collect directly from consumers and have recycled back into food‑grade material by a single accredited reprocessor or exporter. The waste must not be mixed with other materials and must relate to filled packaging first supplied on or after 1 January 2024. Evidence must come from accredited operators.
Closed‑loop offsetting carries a dedicated charge and fixed deadlines. For 2024 and 2025 data, producers may resubmit amended figures by 28 January 2026, paying a single £2,548 charge to cover both years. To use the closed‑loop route for 2026, a further £2,548 must also be paid by 28 January 2026. Offsetting is unavailable if the charge is not paid.
Producer attribution in supply chains is clarified. Once the first producer has supplied packaging, no other person becomes a producer by making further supplies, other than a seller. Where components are added after first supply-such as new labels-producer status for the added component is determined under the standard role rules. Multi‑brand packs are attributed either to the brand owner making first supply or to the brand occupying the largest external surface area.
Corporate transactions are placed on a firmer statutory footing. New provisions set out how merged entities are classified as large or small in the year of merger and the following year, how historic obligations and any existing PRNs/PERNs transfer, and how disposal and administration fees are allocated where liabilities pre‑date completion. Brand or business transfers trigger re‑registration and reporting by the transferee within 28 days, with certain recycling obligations shifting from the transferor to the transferee. These changes align with regulator guidance on how group restructures affect obligations and fees.
Reporting and evidence duties are strengthened. Large producers must retain data and reprocessor/exporter evidence for seven years, and where closed‑loop tonnages are claimed they must hold proof that all eligibility conditions are met, including end‑use as food‑grade material and the identity of the single reprocessor handling the waste stream. Evidence must be from accredited operators and available to regulators on request.
Fee calculation is adjusted in two material ways. First, where closed‑loop tonnages are properly reported and the additional charge has been paid, the scheme administrator must offset those weights against household packaging supplied when calculating disposal fees. Second, modulation is broadened: from 2026 the administrator may consider whether the amount of packaging used is no more than reasonably necessary for its purpose when setting fees. Base fees and modulation policy are anchored in the joint four‑nation policy framework and PackUK’s published approach.
The scheme administrator is enabled to appoint a Producer Responsibility Organisation (PRO), subject to four‑nation consent. A PRO must be a not‑for‑profit body (but not a charity) and can be tasked to deliver specified functions or provide advice and support. Appointment, variation and revocation conditions are set out to protect continuity of service, including the ability to transfer essential data, contracts and systems to a successor to maintain scheme operations. The Welsh Government’s statement confirms this enabling step within the wider pEPR refinement package.
Enforcement is updated to support data quality and market integrity. It becomes an offence to submit closed‑loop data without having paid the additional charge, and reprocessors/exporters are prohibited from issuing duplicate PRNs/PERNs for the same packaging waste. Scotland‑specific offences are added for licensors and pub operating businesses where Schedule 10 data duties are not met, aligning enforcement with devolved alcohol licensing structures.
Timetables matter for finance teams. Key dates now include: 28 January 2026 for resubmitting 2024–25 closed‑loop data and paying the combined charge; April 2026 for the January–June 2025 closed‑loop window; and October/November assessment cycles for disposal and administration fees as set out by PackUK. Organisations seeking to use closed‑loop offsets in 2026 must settle the charge by 28 January 2026 and assemble accredited evidence ahead of reporting.
What this means in practice: packaging leads should review material categorisations against the new fibre‑based composite and paper/board rules, confirm whether any food‑grade plastic collections qualify for closed‑loop status, and check M&A plans against the new merger/transfer provisions before completion to avoid missed registrations. Finance directors should update 2026 fee forecasts to reflect potential closed‑loop offsets and emerging modulation for ‘no more than necessary’ packaging, ensuring evidence and sign‑off processes meet regulator expectations.