The UK has approved final changes to its extended producer responsibility (EPR) regime for packaging, with measures taking legal effect on 1 January 2026. The Statutory Instrument confirms four‑nation consent and was signed on 17 December 2025, setting out how producers will fund household packaging waste and how data must be reported. This is a policy lever to improve recycling outcomes without apocalyptic rhetoric-clear rules, firmer evidence, and stronger accountability.

The headline shift is a new way for brands to reduce their disposal fees by proving genuine “closed‑loop” recycling of food‑grade plastic they supplied. To qualify, a producer must collect the used packaging directly from its customers, keep it uncontaminated by other producers’ waste, and send it to one accredited reprocessor (or its overseas equivalent) where it is recycled back into food‑grade material. Only evidence from an accredited reprocessor or exporter counts.

There is an extra charge to use this offset. Producers that want to report closed‑loop tonnages must pay £2,548 for 2024/25 data by 28 January 2026, and the same amount again to use the offset for 2026 data. The government has published the reporting windows and the evidence standard, including what reprocessors must confirm and how producers validate claims. Attempting to report closed‑loop without having paid the charge is an offence.

Evidence expectations are tougher. Producers must retain data and supporting documentation for seven years, cannot “double count” material, and-except during a one‑off switch of reprocessor mid‑period-may not aggregate closed‑loop tonnages from multiple reprocessors. These details are designed to tighten audit trails and prevent inflated offsets.

Fee calculation rules are also updated. Closed‑loop tonnages can reduce a producer’s household packaging baseline for disposal fees, but only if the additional charge has been paid; the scheme administrator may estimate data for late‑identified liable producers and apply interest, with a four‑year backstop (ten years where obligations were evaded). This gives PackUK clearer powers to recover costs and curb free‑riding.

EPR pricing is evolving in two stages. For 2025–26, PackUK has set per‑tonne base fees across materials-indicatively £423 for plastic, £196 for paper/card, £192 for glass, £266 for aluminium, £259 for steel and “other”, £280 for wood, and £461 for fibre‑based composites-used to generate invoices first issued in October 2025. From 2026–27, fees will be modulated so hard‑to‑recycle formats pay more and highly recyclable designs pay less, based on the government’s Recyclability Assessment Methodology.

Material definitions are clarified to reduce grey areas. “Fibre‑based composite” now covers paperboard with plastic layers that cannot be separated by hand, while packaging with plastic layers at or below five per cent by mass can be treated as paper or board if evidence is held. Packaging in scope of a deposit return scheme remains exempt, including where a low‑volume line exemption applies.

Rules on who is the “producer” on a pack are tightened. Where multiple brands appear, liability follows either the brand that first supplied the filled pack or, failing that, the brand with the largest visible area. Once a first producer supplies the packaging, only a seller can subsequently become a producer for that same item; new components added later-such as labels-create their own producer responsibilities.

Corporate events get dedicated provisions. Mergers and brand or business transfers now come with clear duties to re‑register within 28 days, resubmit data for the current and previous year, and shift recycling obligations and any PRNs/PERNs to the acquiring entity. This removes ambiguity that previously complicated compliance during restructures.

Charities are no longer outside the regime entirely. They are exempt from producer obligations and from annual disposal and administration fees, but charity reprocessors and exporters must register from 1 January 2027; enforcement for charity operators is paused until then. This balances burden reduction with a route to full regulatory coverage.

Integrity of recycling evidence is reinforced. Accredited reprocessors and exporters must not issue PRNs or PERNs more than once for the same packaging waste, and accreditation conditions are clarified. These changes target fraud risk and improve confidence in the UK’s evidence system.

The scheme administrator gains the ability to appoint not‑for‑profit Producer Responsibility Organisations (PROs) to run specified functions, with guardrails on governance and performance and the option to transfer essential assets if a PRO is replaced. The administrator is operating as PackUK in Year 1, with government confirming its role and timetable.

What this means in practice is straightforward. Brands planning to claim closed‑loop offsets should finalise take‑back or mail‑back systems now, appoint a single accredited reprocessor for each stream, and prepare auditable evidence trails. Finance teams should budget for the £2,548 closed‑loop charge by 28 January 2026 and check whether any 2024–25 data can be amended to secure legitimate offsets.

The update lands against improving but uneven recycling performance. Government figures indicate UK packaging recycling reached around 75% in 2024 using the new methodology, while plastic packaging remains the laggard at roughly 54–55% in recent assessments; WRAP’s Plastics Pact reports steady gains in recyclability and recycled content. New domestic capacity-such as Veolia’s food‑grade plastics plant due in early 2026-should help turn policy clarity into real circular flows.