UK Extended Producer Responsibility for Packaging: Shifting Waste Costs from Taxpayers to Producers

Overview

The UK’s Extended Producer Responsibility (EPR) for packaging is an environmental policy introduced under the Environment Act 2021, with detailed rules contained in the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. Effective from January 2025, this framework replaces the older Packaging Waste Regulations 2007, significantly expanding producer obligations to cover the full net costs of managing packaging waste, including collection, recycling, and disposal. The Department for Environment, Food & Rural Affairs (Defra) oversees implementation in England, while devolved administrations manage compliance in Scotland, Wales, and Northern Ireland. Although the UK is no longer an EU member, the EPR aligns with the EU’s Circular Economy Package and its updated Packaging and Packaging Waste Directive (PPWD), reflecting global trends toward shifting waste management costs from taxpayers to producers.

Reporting requirements

Under the EPR regulations, affected companies must report detailed packaging data biannually via the Report Packaging Data (RPD) service, including material type (e.g., plastic, glass), weight, packaging category (primary, secondary, etc.), and "nation data" (where packaging is sold/discarded in the UK). Large producers (turnover ≥£2M handling >50 tonnes/year) submit data by 1 October (Jan–June) and 1 April (July–Dec), while small producers (turnover ≥£1M handling 25–50 tonnes/year) report annually by 1 April. The payment of packaging base fees is a key aspect of compliance with the EPR scheme. The fees directly tie producers' financial obligations to the type and quantity of packaging they place on the market. The base fees vary by material, reflecting differences in recycling costs and environmental impact. As set in June 2025, the illustrative base fees for 2025–2026 are:

• Plastic: £423/tonne

• Fibre-based composites: £461/tonne

• Aluminium: £266/tonne

• Steel: £259/tonne

• Wood: £280/tonne

• Glass: £192/tonne

• Paper/board: £196/tonne

• Other materials (e.g., bamboo, cork, and rubber): £259/tonne

Affected entities also need to present evidence notes called Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs). To facilitate reporting, several packaging software options are available such as PackTotal EPR and ForSURE, which automate data categorization, validation, and submission, reducing reliance on manual processes. Affected entities can also use the services of compliance schemes which are registered third parties that help organizations meet the EPR for packaging requirements.   

Penalties for Noncompliance

Non-compliance can trigger fixed fines of £1,000 (rising to £1,500 if unpaid within 56 days) for minor breaches like late submissions or failure to maintain records, while serious violations (e.g., failure to register or report) risk variable penalties of up to £3 million. The Environment Agency may also recover enforcement costs and publicly name non-compliant firms, causing reputational harm. Companies must retain records for seven years to withstand audits, with inaccurate data potentially classified as fraud. Enforcement undertakings (voluntary corrective plans) may mitigate penalties, but proactive compliance via software and expert consultation is advised.

Current Status and future outlook

The UK’s EPR scheme for packaging is now fully active. Financial obligations began in January 2025, and from 2026 fees will become more tightly aligned with each material’s environmental impact and recyclability, commonly referred to as modulated fees based on the Recyclability Assessment Methodology (RAM). DEFRA maintains a public register of producers.

In March 2026, PackUK announced the appointment of UK Packaging PRO as the Producer Responsibility Organisation (PRO) for the scheme, with responsibilities phased in from April 2026. The PRO introduces an industry-led operational layer, working alongside PackUK to support delivery and bring producer input into how the system functions in practice.

At the same time, early signs of legal and interpretive friction are emerging. In March 2026, Fever-Tree launched a formal legal challenge against the Environment Agency, arguing that certain glass bottles supplied to the hospitality sector should be excluded from EPR obligations. The case reflects broader uncertainty around scope definitions, particularly the distinction between household and non-household packaging.

Looking ahead, the UK’s Deposit Return Scheme (DRS) is scheduled to launch in 2027. While legally distinct from pEPR, it is designed to operate alongside it, targeting beverage containers specifically and introducing a consumer-facing deposit incentive to increase collection rates. Together, the two policies form complementary parts of the UK’s wider packaging waste and circular economy framework.

Overall, the scheme is transitioning from initial implementation to operational refinement. Although some disputes and compliance challenges are emerging, there is no indication at this stage that they will alter the core direction of the policy.

Resources

• https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do

• https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-recycling-obligations-and-waste-disposal-fees

• https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-2025-base-fees

• https://www.gov.uk/government/collections/extended-producer-responsibility-for-packaging-report-packaging-data

• https://report-packaging-data.defra.gov.uk/public-register

• https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-register-of-packaging-compliance-schemes

• https://npwd.environment-agency.gov.uk/public/publicsummarydata.aspx