UK EPR packaging rules: key changes from Jan 2026

From 1 January 2026 the UK’s packaging rules change again under Extended Producer Responsibility (EPR). If you put brands on packaging, pack or fill products, import goods, or operate an online marketplace, this update affects how you register, what you report, and the fees you pay. The Statutory Instrument was made on 17 December 2025 and starts from New Year’s Day 2026 across England, Scotland, Wales and Northern Ireland.

Let’s set the scene. EPR moves the cost of dealing with household packaging waste from councils to the businesses that place that packaging on the market. The four governments say this is about using less material, making more of it reusable or recyclable, and cutting carbon across the packaging life cycle. PackUK acts as the scheme administrator.

Who pays? Under the 2024 Regulations, you become a “liable producer” for disposal and administration fees if you are a large producer and, in the previous calendar year, you were a brand owner, packer/filler, importer or first UK owner, distributor, online marketplace operator or service provider-and you supplied household packaging.

The 2025 amendment clarifies several definitions you’ll use when sorting your data. A big one is the paper test: packaging made of paperboard with plastic layers can still count as “paper or board” if the plastic is 5% or less by mass and you can evidence it; otherwise it sits in “fibre‑based composite”. This matters because fees and targets differ by material.

You’ll also see a new carve‑out linked to deposit return schemes. Anything that is, or would be, a deposit item (but for a small‑volume exemption) is treated as exempt packaging for EPR purposes. That stops double‑charging once deposit systems go live at scale.

Now to “closed loop” recycling-a phrase you’ll hear a lot. In EPR, this means food‑grade plastic household packaging that your business supplied on or after 1 January 2024, which a consumer returns directly to you (or your agent), kept separate from other producers’ material, and which you send to a single reprocessor to be made back into food‑grade plastic again. Evidence must come from an accredited reprocessor or exporter.

Why does closed loop matter? If you do it properly and pay the extra registration charge for the year in question, you can report your closed loop tonnage and the scheme administrator will offset it when calculating your disposal fee-reducing what you owe. Without that extra charge, you cannot take the offset. Keep all data and evidence for seven years.

Fees are meant to shape design choices. Government sets base fees by material for household packaging; for 2024 placements invoiced from October 2025, guidance lists around £423 per tonne for plastic, £196 for paper and card, £461 for fibre‑based composite, £192 for glass, £266 for aluminium, £259 for steel and £280 for wood. From 2026/27, “modulation” will adjust fees to reward easier‑to‑recycle and reusable packaging.

There is also a new signal on cutting unnecessary material. When the scheme administrator modulates fees, it may consider whether you have used no more than the amount of packaging reasonably necessary for the job. In short: lighter, right‑sized packs can lower costs over time if they remain recyclable and safe.

Mergers and brand sales get clearer rules. After a corporate merger, the new company steps into the shoes of the merged bodies for ongoing obligations and may have to register quickly, aggregate data for the merger year, and take on any unpaid fees. If you buy a brand or part of a business, you must notify your regulator within 28 days and, for set periods, you may be treated as a large producer based on combined turnover and packaging tonnage.

If the brand you acquire carried recycling obligations, those obligations move to you. Both buyer and seller must re‑submit data for recent reporting periods so the right party pays the right fees, and PRNs/PERNs can transfer across to show compliance. This avoids gaps in evidence when a label changes hands mid‑year.

Charities see a shift too. Rather than being outside the whole regime, charities are now only exempt from the parts that apply to producers. If a charity operates as a reprocessor or exporter, the registration and offence provisions apply later, with a grace period until 1 January 2027 before those obligations bite.

Reporting rhythm stays familiar for large producers: submit January–June data by 1 October and July–December data by 1 April. That timetable helps the scheme administrator set fees and local authority payments. If you discover mistakes, you must amend your report and keep the evidence trail.

Late assessments are now on the books. If the scheme administrator later discovers you should have been a liable producer, it can issue a notice and calculate what you owe; interest can be charged from the date the payment would have fallen due. There’s a four‑year limit in normal cases, extending to ten years where non‑compliance blocked a timely assessment.

What this means for you if you design packs: start with recyclability and material minimisation. The paper/board 5% plastic rule could move some cartons or cups into a cheaper category-but only if you can prove the plastic fraction. If you supply food‑grade plastic packs and can bring them back cleanly from customers, a closed loop can cut fees and signal your circular credentials.

A quick glossary to keep at hand. EPR is a “polluter pays” rule for packaging, making businesses fund the net costs of managing household packaging waste. “Liable producer” is a large producer supplying household packaging that must pay disposal and admin fees. A “PRN/PERN” is evidence bought from accredited reprocessors/exporters to show you funded recycling. The “scheme administrator” (PackUK) runs fee setting and payments. A “Producer Responsibility Organisation” may be appointed to carry out parts of that job under government oversight.

Final step‑by‑step for January: confirm whether you are a large producer; check your packaging categories against the new paper/board and fibre‑composite definitions; decide whether a closed loop is realistic in your supply chain and line up an accredited reprocessor; make sure your contracts cover data‑sharing during any merger or brand sale; and keep evidence organised for seven years.

Why now? Ministers want EPR to drive a shift to packaging that uses less material and stays in use for longer, while ensuring producers-not taxpayers-cover the bill for household packaging waste. That’s the policy spine running through the 2024 Regulations, the 2025 amendment and the joint Four Nations statement.