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Packaging rules unpacked: updates to UK’s Extended Producer Responsibility for packaging (pEPR) legislation and programme

The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 consolidates and updates legislation which underpins the UK’s Extended Producer Responsibility for packaging (pEPR) programme.

Introduced in December 2024, the new Regulations revoke a variety of previous legislation covering data reporting for packaging, whilst The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 and The Producer Responsibility Obligations (Packaging Waste) Regulations (Northern Ireland) 2007 will be revoked on 1st January 2026.

 

The Regulations set out requirements for large and small producers of packaging to register and report data on packaging supplied in the United Kingdom, paying fees to contribute towards the disposal and recycling of packaging waste.

Producers of packaging are those established in the UK that supply packaging as:

  • a brand owner (whose brand appears on packaging);
  • a packer/filler (who fill packaging);
  • an importer or first UK owner;
  • a distributor (who supplies unfilled packaging to a 3rd party);
  • an online marketplace operator;
  • a service provider (who supplies reusable packaging through hire or lending); or
  • a seller.
  • Large producers are those with an annual turnover greater than £2 million which produce more than 50 tonnes of packaging per calendar year.
  • Small producers are those with an annual turnover greater than £1 million, which produce more than 25 tonnes of packaging per calendar year.

 

As with existing requirements, producers of packaging can register and report on the packaging they supply directly themselves through PackUK, who have been established as the scheme administrator on behalf of the authorities of the four UK nations. Alternatively, producers can become a member of a registered compliance scheme, which will cover registration and reporting requirements on their behalf.

 

Registration is required by 1st April 2025 for 2025 and then from:

  • 1st October 2025for 2026 and then 1st October in the year preceding the relevant year for large producers (except sellers); or
  • 1st Aprilin the relevant year for small producers and sellers.