The UK has approved updates to its packaging extended producer responsibility rules that take effect on 1 January 2026. Ministers in all four nations consented, keeping the scheme UK‑wide and aligning it with the environmental outcomes set out in this year’s joint policy statement. The direction of travel is clear: lighter packs, more reuse, and higher‑quality recycling paid for by those placing packaging on the market.

A new closed‑loop incentive now recognises brands that collect their own food‑grade plastic packaging from customers and turn it back into food‑grade material. Where strict conditions are met, the tonnage recycled this way can be set against household disposal fees, lowering bills for firms that design for true circularity.

To qualify as closed loop, the waste must be the brand’s own food‑grade plastic placed on the market from 2024, collected directly from consumers without mixing with other brands’ material, and recycled by a single accredited reprocessor back into food‑contact plastic. Evidence must show each step, from collection to reprocessing, and be kept for seven years.

There is an administrative gate to claim these credits. Large producers that want to report closed‑loop tonnages must pay an additional registration charge and keep auditable records from accredited reprocessors or exporters. Reporting is tied to the scheme’s twice‑yearly data cycle, with new offences for claiming without paying the charge.

Fee modulation is being sharpened. From 2026/27 the Scheme Administrator must use modulation to reward easier‑to‑recycle or reusable formats, and-importantly for pack designers-can vary fees where the amount of packaging used is no more than reasonably necessary for its job. Expect clearer, published policies on how design choices change what you pay.

Material definitions have been tidied up to reduce reporting disputes. A fibre‑based composite with plastic layers can be counted as paper or board if the plastic is 5% or less by mass, providing evidence is held. That matters for both recyclability claims and fee calculations.

Charities are no longer excluded from the regime entirely. They’re exempt from producer obligations and disposal/administration fees, but charity reprocessors and exporters will need to register and meet accreditation timelines by 1 January 2027. This gives the sector breathing space while keeping audit trails intact.

Business changes get clearer rules. After a merger, only the first supplier remains the producer for that packaging unless a new component is added. New regulations also spell out what happens when brands or parts of a business are sold: both parties must re‑report for current and prior periods, and obligations move with the brand to avoid gaps-and free‑riders.

Deposit return schemes are referenced too. Packaging in scope of a “relevant deposit scheme”-including low‑volume line exemptions-sits outside parts of the EPR regime. With England, Scotland and Northern Ireland now planning DRS launches for October 2027, and Wales aligning its timetable, brands should plan EPR and DRS compliance together.

Enforcement has more bite. The scheme administrator can retrospectively assess disposal and administration fees where producers should have been in scope, using best‑available estimates if no data was filed. Interest can be charged where late discovery stems from non‑compliance. Duplicate PRNs/PERNs for the same waste are explicitly banned.

Charges and running costs are updated. Registration and accreditation fees for producers, exporters and reprocessors have risen, with an added £2,548 option for large producers to report closed‑loop tonnages. The administrator can also budget for functions delivered by a Producer Responsibility Organisation-an independent not‑for‑profit expected to work alongside PackUK from 2026.

Why this matters: quality recycling is still lagging. WRAP reports that 71.6% of plastic packaging is now reusable or recyclable, but “effective recycling” sits around 53% and average recycled content at 28%. EPR’s new signals-closed‑loop credits and packaging‑minimisation modulation-are designed to improve those numbers while cutting emissions.

What brands should do now: audit any take‑back or refill models against the closed‑loop test and set up evidence chains with a single accredited reprocessor; run fee scenarios using lighter formats and mono‑materials; refresh M&A and brand‑licensing clauses so reporting and liabilities transfer cleanly; and prepare for stricter data assurance in 2026. If you rely on co‑mingled collections, keep an eye on the Scheme Administrator’s recyclability methodology and local‑authority cost guidance.

One final point on timing. The amendments were made in mid‑December 2025 and apply from 1 January 2026, with specific transitional deadlines in early 2026 for amended reports and optional closed‑loop charges. Treat January–March as your setup window; after that, late assessment powers and interest provisions start to matter.