The UK has signed off changes to its extended producer responsibility (EPR) regime for packaging, with the Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025 made on 17 December and in force from 1 January 2026 across England, Scotland, Wales and Northern Ireland. The update refines fees, definitions and reporting so money flows toward genuinely recyclable designs and waste prevention.

A new closed‑loop offset recognises brands that collect their own food‑grade plastic packaging back from customers and recycle it into food‑contact materials again. To qualify, the waste must be taken directly from the consumer by or for the same producer, kept separate from other producers’ material, and sent to a single reprocessor; producers must keep evidence from an accredited reprocessor and retain records for seven years. The offset applies only where the recycled output meets food‑contact standards in Commission Regulation (EU) No 10/2011 and, for recycled plastics, Regulation (EC) No 282/2008.

There is an additional charge for reporting closed‑loop offsets. For 2026 the government lists a provisional £2,548 per producer to activate closed‑loop reporting, alongside updated registration fees. That price point is meant to reflect the extra verification and administration required, and it sits beside the standard registration charges for large and small organisations.

Material definitions are tightened to push design change. Paper or board packaging that contains plastic layers may still be declared as paper/board if the plastic is no more than five per cent by mass; beyond that threshold, the pack is a fibre‑based composite. Expect teams to model weight reductions and swap laminates to stay at or below five per cent, especially for dry‑goods packs.

This matters because recyclability ratings and disposal fees pull in the same direction. Under PackUK’s Recyclability Assessment Methodology (RAM), producers receive red/amber/green outcomes that feed modulated charges; from 2026, the scheme administrator can also consider whether the amount of packaging used is no more than reasonably necessary when setting fees. In short: fewer, simpler materials cut cost exposure.

The rules also align with incoming deposit return schemes (DRS). Packaging that is, or would be, a deposit item under a relevant DRS is treated differently in EPR, with provisions for low‑volume line exemptions. The UK, Welsh, and Scottish governments and DAERA have fixed an October 2027 DRS launch, appointing a Deposit Management Organisation to run the system. Brands planning return‑to‑store loops should map EPR, closed‑loop and DRS obligations together.

Corporate changes are covered in depth. New provisions set out how mergers and brand or business transfers are treated, including who is the ‘producer’ after a sale, when to re‑register, which party carries recycling obligations, and how PRNs/PERNs can be moved. In practice: integration teams will need packaging data, evidence and PRNs alongside contracts on day one.

Administration has been sharpened. Producers must notify regulators within 28 days of ceasing to be a producer; evidence and data must be kept for seven years; and the scheme administrator gains powers to make late assessments where a liable producer was missed, with interest where non‑compliance caused delay. Penalties escalate for reporting closed‑loop data without having paid the extra charge.

Charges are uprated from 1 January 2026, subject to final confirmation. Provisional fees listed by Defra include £2,842 to register a large producer directly (£1,803 via a compliance scheme), £1,303 for small producers (£696 via a scheme), late fees, group subsidiary rates - and the £2,548 closed‑loop reporting charge. Budget holders should hard‑code these figures into 2026 compliance plans.

What does good look like under the new rules? WRAP’s latest UK Plastics Pact report shows members averaging 28% recycled content across plastic packaging, 71.6% reusable or recyclable designs, and eliminating roughly 700 million problematic items since 2018 - progress that correlates with lower modulated fees. That’s the sort of data‑backed design shift EPR is built to accelerate.

Closed‑loop is no longer theory. A UK sprint trial led by Faerch with major retailers, brands and recyclers proved that kerbside‑collected PET trays can be recycled back into food‑grade trays domestically, protecting material quality and avoiding downcycling. That kind of single‑reprocessor, food‑grade pathway is exactly what the offset recognises.

Two planning notes as 2026 starts. First, align packaging changes with Simpler Recycling - from 31 March 2026, councils in England must collect core dry recyclables and weekly food waste, and OPRL expects drink and food cartons to carry a Recycle label from 1 April 2026 as kerbside coverage clears 75%. Second, treat RAM ratings and minimisation as design inputs, not afterthoughts - they now influence what you pay.