Packaging Extended Producer Responsibility: Unboxing a new era

Introduction

It’s all change in the world of packaging waste management. The packaging reporting deadline has passed. From October 2025, businesses that fall under the UK’s Extended Producer Responsibility for packaging (pEPR) scheme will receive their first invoices, covering the period from 1 April 2025 to 31 March 2026.

To recap, pEPR shifts the cost of dealing with waste packaging away from local authorities to the businesses that produce it. The new system is expected to generate around £1.5 billion a year for councils to spend on collecting and managing packaging from households. Although not officially a tax, many businesses are seeing it, and talking of it as one.

The policy also aims to reduce the use of excessive packaging, particularly single-use plastics, by incentivising companies to adopt more sustainable practices. While some sections of the business world are concerned about the extra cost pressure of pEPR, the government argues that households will benefit, while environmental groups support the policy as a necessary step to address packaging waste.

pEPR is finally here: Are you ready?

Businesses are no strangers to red tape, but October 1st represents a compliance deadline with a difference. It's the beginning of a major transfer of environmental costs. The weight-based charging system means a glass jar of premium honey will cost significantly more to dispose of than lightweight plastic alternatives, while plain cardboard packaging sits somewhere in between as it is easily recyclable.

As John Redmayne, Managing Director of ERP UK, explained on BBC Breakfast[1] (30.09.25): "It's a very big bill. There's a total cost of about one and a half billion pounds per year to be shared out amongst producers in the UK. Packaging EPR is a very simple idea, but getting it right, getting it fair, and getting everybody on board with the detail of it involves a lot of complexity."

John also spoke to Naga Munchetty on BBC 5 Live (01.10.25) saying: “These new rules now make it very clear what the definition of recyclable is, within the context of the current system in the UK for collecting packaging from households. Over the next three years we will see those companies that place recyclable packaging on the UK market, gradually face lower EPR costs compared to those that aren’t using recyclable packaging.”

He added: “The laudable thing is that EPR is aligning commercial incentives, with environmental incentives. However, getting all that to work in the system is complicated, and involves companies having to collect and submit a lot of data, and then pay significant bills. Those are the two big changes companies are having to navigate.”

These first invoices, officially called ‘Notices of Liability’, will cover the period from 1st April 2025 to 31st March 2026. Whether you're a craft brewery using glass bottles, a tech company shipping in protective plastic, or a shoe retailer using branded cardboard boxes, your liability will be calculated based on packaging data submitted for 2024, accessed through the Report Packaging Data (RPD) system.

Why this matters: Aligning incentives with environmental good

For the first time, we have genuine alignment between financial incentives and environmental good practice. At ERP UK we consider this to be about more than cost transfer. It's creating market drivers that reward sustainable choices.

Companies using recyclable packaging that meets the new definitions will see lower costs, creating real market demand for sustainable packaging choices. A coffee roaster switching from mixed-material pouches to recyclable alternatives, or a beauty brand redesigning glass containers to reduce weight, will directly benefit from lower pEPR fees.

The system establishes a direct financial link between packaging decisions and environmental impact, encouraging businesses to consider the full lifecycle of their products.

The transparency is equally important. There's now a public register where companies can verify their suppliers and competitors are registered and contributing fairly. No hiding, no free-riding.

The opportunity ahead: Driving innovation

This system creates the market drivers for packaging innovations that campaigners, government and progressive producers have been calling for. We're talking about lighter materials, better recyclability and reduced environmental impact becoming financially advantageous choices.

While everyone's focused on compliance and data accuracy today - and rightly so - the longer-term benefits are transformational. Companies that embrace these data requirements and use the insights to optimise their packaging choices will be the winners in this new landscape.

As John Redmayne explained when interviewed by the BBC: “Businesses know the change has gradually been coming towards us since 2018. At ERP UK we have been advising and guiding companies with understanding the changes, and making sure they are prepared.”

He added: “But the final details, for example, defining what is considered recyclable and what isn’t under this system, were only released at the start of this year. And the final identification of the cost for each material type was only confirmed at the end of June this year. So, there has been an ability to prepare for companies, but in terms of making final decisions, we think that is going to become a lot easier from this point, because companies now have the information they need. They can turn that into financial plans, and they can also start making decisions about changing the packaging they are using.”

Preparing for payment: Essential steps

To ensure smooth processing of your first invoice:

• Verify your RPD system access - only registered users can access invoices
• Ensure your finance team has system access if they'll handle the payments
• Review your 2024 packaging data for accuracy
• Prepare payment processes - you can pay in full within 50 days or sign up for a four-instalment plan

Remember, these invoices are statutory debts with significant late payment penalties: 20% of unpaid fees or 5% of UK turnover (whichever is greater).

If all of the above sounds difficult to achieve, it’s worth contacting a specialist recycling platform, like ERP UK for support. Our stated aim is to help companies of all sizes comply with recycling and reporting regulations, and be future-ready for the circular economy.

Our expert team will lead you through the process, ensuring your packaging data is as accurate as possible and that you remain compliant. For total peace of mind, we check your data with a fine-tooth comb before submission. What’s more, our knowledge of the packaging market means we always get the best value recovery and recycling evidence for you.

A system finding its feet

While the pEPR system may have kicked into action, it’s still evolving. Businesses should expect ongoing refinements to base fees, label alignment with EU requirements, and tweaks to the recyclability assessment methodology.

However, the direction is clear. This represents a fundamental shift towards a circular economy where producers take responsibility for their packaging's entire lifecycle.

Let’s welcome the change. Companies that seize this moment to drive sustainable innovation will emerge stronger in the new landscape.

For support with pEPR compliance, visit gov.uk/government/news/preparing-for-pepr-year-1-invoicing-key-information-for-liable-producers or contact ERP UK for expert guidance on navigating these new obligations.

Related services

Extended Producer Responsibility - visit the webpage here

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