The UK has signed off new rules that reshape extended producer responsibility for packaging from 1 January 2026. The Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025-approved by both Houses and signed by Parliamentary Under Secretary Mary Creagh on 17 December-tighten fee calculations, reward closed‑loop plastics, and formalise how mergers and brand sales are handled across England, Scotland, Wales and Northern Ireland.

The centrepiece is a clear legal route for producers to lower disposal fees by proving genuine closed‑loop recycling of their own household plastic packaging into food‑grade materials. To qualify, the waste must come back directly from consumers to the same producer, remain segregated from other producers’ material, and be recycled by a single reprocessor into food‑contact‑compliant outputs. The rules reference Commission Regulations (EU) No 10/2011 and No 282/2008 for food‑contact standards, underscoring quality and safety as non‑negotiables.

Closed‑loop offsets now sit alongside existing credits for ‘relevant packaging waste’ sent for recycling. Crucially, producers may only claim the new closed‑loop credits if they pay an additional registration charge of £2,548 and hold evidence from an accredited reprocessor or exporter. Where attempted offsets exceed the household packaging a business actually supplied in the baseline year, the offset is disallowed-closing an obvious loophole.

Evidence and audit trails harden. Producers must retain mandated data and proof for at least seven years, including traceable chains of custody showing direct consumer returns, single‑reprocessor handling and final recycling into food‑grade plastics. With no aggregation of multiple reprocessors allowed within a period-except during a switch mid‑period-the policy leans into verifiable, circular flows rather than paper‑based claims.

Fee modulation is sharpened to reward design that genuinely uses less material. The scheme administrator can now consider whether a pack uses no more packaging than is reasonably necessary for its purpose. This gives legal bite to minimisation, long championed by Defra’s UK joint policy statement on EPR, and aligns with industry programmes that prioritise elimination and lightweighting where performance allows.

Market integrity measures are tightened. Reprocessors and exporters must not issue duplicate PRNs or PERNs for the same waste stream, and accreditation cross‑references are cleaned up. The scheme administrator can make late assessments where a liable producer was missed, estimate data using best available evidence, and charge interest-up to four years back, or ten where non‑compliance blocked earlier assessment.

Responsibilities are clarified across complex supply chains. Where several brands appear on a pack, the brand making the first supply, or the brand with the largest surface area if none made the first supply, is the producer. Adding new components-like labels-can create new producer obligations for that component. Deposit return scheme items are excluded, including low‑volume lines that are exempt within DRS rules, reducing double charging.

Mergers and acquisitions get a full compliance playbook. After a merger, the combined entity is treated as large if any party was large and must register by the earliest applicable date or within 28 days. It inherits continuing obligations, can take on PRNs/PERNs from predecessors, and may owe disposal and administration fees for the assessment year. Brand or business buyers must notify regulators within 28 days, re‑register if thresholds are triggered, and-importantly-re‑report data so packaging supplied pre‑transfer with the acquired brand is treated as if supplied by the buyer.

Material definitions shift to favour clearer design choices. Fibre‑based composites are now distinguished from ‘paper or board’ using a 5% plastic‑by‑mass threshold. If a pack’s plastic layers are at or below five percent, it can be reported as paper or board. That clarity should accelerate mono‑material designs and improve sortability without penalising necessary barrier layers.

Charities are no longer wholly outside the regime. They are exempt from core producer obligations and annual fees, but charity reprocessors and exporters must register from 1 January 2027, with offences and civil sanctions phased in after the transition. Charges across producer registrations, compliance schemes and reprocessor accreditations increase in line with inflation and new administrative demands.

Transitional windows matter. Large producers can amend 2024 and first‑half‑2025 reports to recognise qualifying material, with hard deadlines of 28 January 2026 and 1 April 2026. Closed‑loop reporting for the second half of 2025 is not permitted, but that material can still be counted as ‘relevant packaging waste’. The additional £2,548 charge applies to those who amend or include such data, and must be paid by 28 January 2026.

If you plan to claim closed‑loop credits in 2026, build the operational proof now. Set up a direct‑from‑consumer route that keeps your packaging separate from others, contract a single accredited reprocessor, and document every transfer. Ensure recycled outputs meet food‑contact law, align packaging designs with the new paper/board threshold and minimisation test, and prepare to re‑report swiftly after any merger or brand acquisition.

These changes can move more plastic back into safe, food‑grade cycles while cutting wasteful packaging. WRAP’s long‑running UK Plastics Pact has shown that high‑quality rPET and rHDPE are achievable where sorting, design and end‑market demand align, and the Ellen MacArthur Foundation’s circular economy work points to fee signals as a powerful driver of design change. With the amended EPR rules, producers that prove real circularity and use less material will pay less-those that defer investment will pay more and face retrospective bills.

Local authorities and consumers should also see benefits. When the scheme administrator assesses disposal costs, it must do so in ways that support the environmental effects set out in the policy statement referenced in the Regulations, improving the prospects for consistent funding, clearer labelling and better kerbside outcomes. The direction is pragmatic: reward what works in practice, and back it up with evidence rather than claims.