UK Ministers have signed the Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025, a UK‑wide update to the 2024 framework. The instrument was laid on 3 November, approved by the Commons on 10 December and the Lords on 16 December, and comes into force on 1 January 2026 following four‑nation consent.
Material definitions are tightened. Packaging with plastic layers at 5% or less by mass may be treated as paper or board if evidence is held, while fibre‑based composites are defined where layers cannot be separated by hand. Exemptions also align with deposit return schemes, including a low‑volume line exemption. The Environment Agency has already allowed early use of these definitions for 2025 under RPS 351.
A closed‑loop offset is introduced for food‑grade plastic household packaging collected directly from consumers by the same producer and recycled by a single accredited reprocessor back into food‑grade materials or articles. Producers must keep evidence and, critically, pay an additional charge to report closed‑loop tonnages; without payment, offsets are not available.
Transitional allowances permit amended reporting of eligible 2024 and 2025 data, with deadlines of 28 January 2026 for the 2024 periods and April 2026 for January–June 2025. Ministers told peers that amended 2024 data can be used to revise 2025 invoices, clarifying how the offset applies before full roll‑out in 2026.
Producer status rules are clarified. After the first supply, no one becomes a producer for the same item except a seller, unless a new component (for example, a new label) is added-at which point producer responsibility for that component is determined afresh. Brand‑owner hierarchy is also specified where multiple brands appear, reducing ambiguity in data and fee allocation.
Corporate change is codified. New regulations 27A–27C set out obligations in mergers and transfers: the combined body inherits continuing duties and unpaid fees; PRNs/PERNs may be transferred to demonstrate prior compliance; and transferees face a 28‑day registration window and a three‑year test to determine large‑producer status using adjusted turnover and packaging volumes.
Charges rise from 1 January 2026 and a separate closed‑loop reporting charge applies. DEFRA guidance lists, among others, £2,842 for large producers registering directly, £1,303 for small producers, £2,885 for online marketplaces, £807 for direct resubmissions, and £2,548 to use the closed‑loop offset. Reprocessor and exporter charges also increase, with accreditation bands ranging from £546 to £3,965 and £328 per added overseas site.
Disposal‑fee modulation is broadened. From 2026/27 the Scheme Administrator must use modulation to incentivise more recyclable and reusable packaging, and fee design may consider whether the amount of packaging is no more than reasonably necessary. This aligns local‑authority payment assessments with the environmental effects set out in the joint Four Nations policy statement.
Enforcement is strengthened. The Scheme Administrator gains powers to identify liable producers missed at the initial assessment and, where appropriate, estimate data and levy interest-addressing so‑called free‑riders. Government and industry briefings stress that this is intended to improve fairness and scheme integrity rather than alter core policy.
Governance changes allow appointment of an independent, not‑for‑profit Producer Responsibility Organisation (PRO) to support delivery alongside PackUK, subject to consent from all four administrations. Ministers said the PRO will operate to agreed conditions, with sovereign functions such as data ownership and fee‑setting retained by the Scheme Administrator.
Operationally, producers should now confirm material classifications against the revised definitions, decide whether to use the closed‑loop route and pay any additional charge by 28 January 2026 for 2024–25 data, and plan for 7‑year evidence retention. Large producers involved in acquisitions should map data transfers early to meet the new 28‑day registration and resubmission requirements. Local authorities and service providers should prepare for updated efficiency assessments that emphasise environmental outcomes as well as cost.