pEPR and current state of play 
“The way UK organisations responsible for packaging must carry out their recycling responsibilities has changed” – UK Government Packaging Extended Producer Responsibility (pEPR) Policy 

     2024 ushered in changes to the reporting and financial obligations of producers who handle packaging in the UK. This new Extended Producer Responsibility (EPR) system passes the full financial costs associated with the collection, sortation, and recycling of packaging on to the companies who are responsible for putting that packaging on the market. The new regulations also create a comprehensive and adaptable framework that incentivises recyclable packaging, waste reduction, future labelling requirements, and improved data gathering up and down the supply chain. 

The past couple of years have brought huge upheaval to the packaging sector with a vast increase in the amount and granularity of data required by producers from across the supply chain, increased bi-annual reporting, short deadlines, last-minute changes, and increased costs. But the dust is finally settling, with two full years of reporting under our belts, and the first invoices (Notices of Liability) sent to relevant producers. 

That’s not to say that the next couple of years aren’t full of changes and challenges for producers, but to paraphrase Margaret Bates, the previous interim head of pEPR Scheme Administrator, PackUK; Packaging EPR is here! 

Now that systems are adapting to the new reporting requirements, teams and knowledge are being rooted into companies, and the financial cost has been laid before finance teams, producers are going to have to look forward to the coming years to innovate and develop their packaging to keep their costs in check and to stay competitive in a changing market. 

Development of the RAM (Recyclability Assessment Methodology) and the effect of modulated fees based on those recyclability assessments will be one of the big levers for change. Thankfully, PackUK released a RAM roadmap in October 2025 to give producers an idea of how the methodology will develop until 2030. 

We’ve laid out a timeline of major events for the coming year under some key headings, starting with pEPR updates, fees, and the related Deposit Return System (DRS) regulations. This is followed by a general overview of the wider circular economy and waste collection reforms, before delving into some parallel regulations and how they may affect you as producers. 

Timeline for the coming year 
   Packaging EPR Updates 

• 1st January 2026 – Amended pEPR comes into force 

• Jul 2026 – RAM 2027 expected to be released 

• ‘Summer’ 2026 – Potential update on mandatory labelling 

• Nov 2026 – Potential future regulatory amendments to be debated in parliament 

Reporting Schedule 

• 1st January 2026 onwards – Producers will need to start gathering (where applicable) Self-Managed Organisation Waste data by 1st October 2026, and Nation of Sale and data for Carrier Bags supplied in England for future reporting by 1st April 2027. 

• 1st April 2026 (deadline) – Large producers must report Jul-Dec 2025 packaging data, small producers must report annual 2025 packaging data. 

• 1st October 2026 (deadline) – Large producers must register and report their Jan-Jun 2026 packaging data, including mandatory Self-Managed Organisation Waste data. 

Fees 

• 14th October 2025 – Notice of Liability (NoL) sent to relevant producers 

• 3rd December 2025 (deadline) – Deadline for first payment of NoL 

• 16th December 2025 – Illustrative 2026 base fees (inc. modulation) 

• June 2026 – 2026 base fees published 

• October 2026 – 2026 NoL to be issued

• December 2026 – Illustrative 2027 base fees (with separate fees for rigid and flexible plastic) 

A reminder that producers still also have a PRN obligation alongside their Notices of Liability. PRNs will usually be procured by your compliance scheme if you are registered with one or will have to be self-fulfilled if registered directly with the appropriate authority.

Deposit Return System (DRS) 
     While there is nothing concrete at the moment from UK Deposit Management Organisation (DMO) about their roadmap for 2026, it is expected that they will move from the ‘set-up phase’ of the deposit management organisation to the ‘delivery phase’; building sorting centres, IT systems, setting up return points, details of DRS labelling, system testing and consumer-engagement, to be ready for go-live in October 2027. 

There was confirmation from Defra in October 2025 that Westminster is working with Welsh Government on interoperability with DRS in the rest of the UK.

Circular Economy 

• 31st January 2026 – Circular Economy Strategy (Scotland) consultation closes 
• ‘Spring’ 2026 – Circular Economy Strategy (England) released as a white paper 

Simpler Recycling (SR) 

• 31st March 2026 – Households in England will have to separate recycling (ex. flexible plastics) and collect waste food for Simpler Recycling (SR) Year 2 
• ‘End’ 2026 – Scotland are co-designing a new ‘Code of Practice for Household Waste Recycling’, which might lead to similar policies as SR in England, with an aim to release this as a consultation end 2026. 

Parallel Regulations 
Emissions Trading Scheme (ETS) 
     From 1st January 2026, the voluntary Monitoring, Reporting, and Verification (MRV) only period will begin for the expansion of the UK Emissions Trading Scheme (ETS) into the waste sector. This will enable operators to better understand participation in the scheme and support further policy development by the UK ETS Authority ahead of the waste sector being included in UK ETS, and associated fees, from 2028. 

What this means for you 

     This is crucial work at a crucial time for producers under pEPR. Current estimates are that 20-30% by weight of fossil material waste sent by Local Authorities (LAs) for incineration is in scope of pEPR. This means that from 2028 the cost associated with disposing of this waste via incineration will be included in pEPR disposal costs. 

The good news is that mandatory collection of flexible plastics from households from 31st April 2027 should reduce the amount of fossil wastes being incinerated to temper this cost increase. 

Digital Waste Tracking (DWT) 
     ‘Spring’ 2026 will see the voluntary testing of the Digital Waste Tracking (DWT) system by waste receiving sites in the UK which will lead up to a mandatory rollout for all waste receivers from October 2026. 

What this means for you 

     As the movement and treatment of waste will be traceable, producers will have increased visibility and accountability over what happens to their waste and where it ends up. Producers will need to work with their waste contracts to ensure collections are correctly digitally logged and ensure that their contractors have traceability and are compliant with the new DWT requirements. 

European Packaging Regulations 
     Packaging and Packaging Waste Regulation (PPWR) was implemented in February 2025 (superseding the previous packaging Directive) and is due to take effect in the EU from August 2026, introducing an array of packaging requirements for producers, importers, and manufacturers alike. PPWR aims to prevent and reduce packaging waste (including through reuse and refill systems), make all packaging on the EU market recyclable by 2030, safely increase the use of recycled plastics, and decrease the use of virgin materials. 

What this means for you 

     PPWR will apply to all businesses placing packaging on the EU market, including UK exporters, and it introduces major changes rolling out from 2026 through to 2040, making long-term planning essential. Up to 80% of existing packaging may need redesign to achieve PPWR recyclability and minimisation goals; however, changes to packaging take time, on average a minimum of 2 years, so businesses need to begin preparing for PPWR now. 

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