EPR Conference 2025

Introduction: Key insights for UK businesses

The annual EPR Conference took place on 12^th November 2025, bringing together industry leaders, compliance experts and businesses to discuss the evolving landscape of UK Extended Producer Responsibility. With packaging EPR fees set to reach £1.5 billion annually and the first invoices due in October 2025, the conference delivered crucial insights for businesses navigating this complex regulatory environment.

The industry mood stands in stark contrast to last year, which one attendee recalled as feeling like “Christmas for the EPR world.” Whereas everything was “new and exciting” at the time of the 2024 conference, today’s reality is one of implementation challenges. Despite this "come down" atmosphere, the event proved critical for understanding both the achievements and ongoing obstacles the sector is experiencing.

The current EPR landscape

The UK's EPR framework continues to evolve at pace, fundamentally shifting how businesses approach packaging waste management. Under EPR, financial responsibility for managing household packaging waste sits with the businesses that produce it, with fees calculated based on material type, weight and crucially, recyclability.

This represents a fundamental shift towards a circular economy where producers take full responsibility for their packaging's entire lifecycle.

Recyclability Assessment Methodology: v1.1: The new reality

The Recyclability Assessment Methodology (RAM) v1.1 is now in effect, creating a direct link between packaging design decisions and financial obligations. The system categorises packaging into three clear bands:

• Green: Packaging that meets recyclability standards
• Amber: Packaging with some recyclability challenges
• Red: Packaging that fails recyclability criteria

The financial impact

The financial implications of RAM v1.1 cannot be understated. Packaging rated 'Red' will face escalating fee multipliers that increase substantially over time:

• 2026/27: 1.2x multiplier
• 2027/28: 1.6x multiplier
• 2028/29: 2.0x multiplier

Perhaps most critically, any packaging not assessed through RAM v1.1 is automatically classified as Red, meaning businesses face maximum fees by default.

Key stakeholder updates for Extended Producer Responsibility

 PackUK's position

PackUK used the EPR Conference to clarify their role emphatically. They wanted to be crystal clear: They are not the regulator or designer of the EPR system. As operational executors tasked with implementing government plans, they asked for industry understanding while acknowledging the challenges of being "housed within Defra."

Enforcement intensifies

The UK environment agencies are responsible for regulation of the system, with multiple points of control.  The Environment Agency’s presentation focused on Producer registrations and data – confirming they have completed 220 producer audits this year, with 28 more scheduled before year-end. As well as increased audits, they also highlighted that, they've shifted from criminal to civil standards of proof for prosecutions - lowering the bar from "beyond reasonable doubt" to "on balance of possibilities." This change significantly increases enforcement risk for non-compliant businesses.

However, for their work at the waste management end of the system, the EA faced heavy criticism from exporters and reprocessors for "vague and terse" responses and complex accreditation processes, raising concerns about the compliance certificate system's viability.

Local Authority funding shortfall

Local authorities revealed that EPR funding will only cover approximately 80% of their costs. LARAC representatives debunked "ring-fencing" as an "urban myth," explaining that dedicated EPR funds simply replace existing council budgets rather than providing additional resources.

WEEE compliance beyond packaging

The conference also highlighted ongoing WEEE compliance (Waste Electrical and Electronic Equipment) obligations. Businesses manufacturing or importing electrical and electronic equipment must meet specific requirements covering collection, recycling and comprehensive reporting.

These obligations run parallel to packaging EPR, creating a complex compliance landscape that requires specialist expertise to navigate effectively.

Immediate actions for your business

Based on the conference insights, businesses should prioritise three critical areas:

1. Assess your current position Conduct a comprehensive review of your packaging data, WEEE obligations and overall EPR compliance status. Understanding your baseline is essential before implementing any strategic changes.
2. Engage with RAM The H2 2025 reporting deadline for large producers (including RAM assessments) is 27 February 2026. Assessments take time and so need to be well advanced by now as delays could mean accepting Red ratings and maximum fees for 2026 - a costly decision that becomes more expensive each year. Conference discussions revealed a concerning trend: many packaging designs receiving recent awards are far from ideal for recycling purposes. Examples included vodka bottles in plastic puffer jackets and wine bottles in wooden lattice cages - all automatically assigned Red ratings. This highlights a fundamental misalignment between packaging design trends and EPR objectives.
3. Plan for ongoing changes EPR compliance isn't a one-time exercise. Integrate compliance considerations into your ongoing business processes, from product development to supply chain management.

Watch for Household vs. Non-Household shifts: Many producers are now getting deep into detailed scrutiny of their product data and looking at opportunities to report non-household evidence because it's significantly cheaper. However, the Environment Agency will scrutinise evidence supporting such switches, particularly for "dual use" products sold to both hospitality and retail markets.

Prepare for Textiles EPR: A circular economy plan for textiles will be published in January 2026 and is expected to include EPR, though full implementation may not occur until 2029. Given packaging EPR's decade-long development, the proposed four-year timeline appears "hyper aggressive," as one attendee commented.

Data management: The hidden challenge

One of the most significant challenges emerging from the conference discussions was the complexity of data collection and management. Many businesses underestimate the administrative burden of EPR compliance, particularly around tracking packaging flows and maintaining accurate records for both household and non-household streams.

The conference highlighted that businesses often struggle with:

• Supply chain visibility: Understanding exactly what packaging enters their operations
• Weight calculations: Accurately measuring packaging materials across diverse product lines
• Evidence documentation: Maintaining robust records to support compliance claims
• System integration: Connecting EPR data requirements with existing business systems

Tese data challenges become particularly acute for businesses operating across multiple sectors or those with complex supply chains. The administrative overhead can quickly overwhelm internal resources, making professional data management services increasingly valuable.

The strategic opportunity

While EPR presents compliance challenges, it also creates opportunities for businesses that act strategically. Early adoption of sustainable packaging design, comprehensive data management and proactive compliance planning can deliver competitive advantages including:

• Reduced long-term costs through optimised packaging design
• Enhanced brand reputation through demonstrated environmental leadership
• Improved supply chain efficiency through better data visibility
• Future-proofed operations ahead of regulatory evolution
• Competitive differentiation through superior environmental credentials
• Enhanced stakeholder relationships with environmentally conscious partners

Expert support for complex regulations

The complexity of EPR regulations - from packaging assessments to WEEE and Battery obligations - requires specialist expertise. ERP UK’s Compliance Scheme Membership covers packaging, WEEE and Batteries[2]. We operate all three, making us a one stop shop for compliance. We manage Takeback Programmes, offering comprehensive end-of-life management.

Our data-driven approach, combined with deep regulatory expertise, positions us as a strategic partner for businesses navigating the EPR landscape.

The enforcement reality

Current late fees of £150-£1,000 are "inconsequential" compared to the hundreds of thousands businesses could save by non-compliance, as one conference attendee noted. However, with the Environment Agency's lowered prosecution threshold and intensified audit programme, this calculation is rapidly changing.

First disposal fee payments are expected around 5 December 2025, marking the beginning of regular financial obligations that will likely increase over time.

International divergence creates new challenges

By 2030, all packaging entering the EU market must be recyclable - a requirement the UK lacks. This divergence between UK and EU regulations creates potential barriers for businesses selling in both markets, as the UK's red/amber/green system doesn't align with EU market access criteria.

Looking forward

The EPR Conference 2025 reinforced that environmental compliance is a business imperative that directly affects bottom-line performance. With fees reaching £1.5 billion annually and penalties for non-compliance increasing, businesses must act decisively.

Behind the public support for green legislation, conference discussions revealed ongoing lobbying efforts and significant corporate resistance. However, the regulatory framework will continue evolving, and the fundamentals remain clear: businesses that embrace EPR proactively, invest in proper assessment and partner with compliance experts will thrive in this new environment.

The conference also emphasised the importance of understanding sector-specific implications. Retailers face different challenges to manufacturers, while importers must navigate additional complexities around documentation and evidence. Small businesses often struggle with the proportional impact of compliance costs, while large corporations grapple with the scale of data management across multiple product lines and markets.

Success in this evolving landscape demands strategic thinking about packaging design, supply chain optimisation and long-term sustainability goals. Companies that view EPR as an opportunity to innovate and differentiate will find themselves better positioned as regulations continue to tighten and consumer expectations around environmental responsibility continue to rise.

Ready to navigate Extended Producer Responsibility compliance with confidence?

Contact ERP UK today to discuss how our comprehensive services can simplify your obligations and position your business for long-term success.

Related services

Extended Producer Responsibility - visit the webpage here

About ERP UK

To learn more about ERP UK and our services please visit our About page

Contact us today:

Telephone: +44 (0)20 3142 6452

E-mail: uk@erp-recycling.org

Follow ERP UK on LinkedIn here: