Your essential EPR compliance roadmap

EPR resolutions for 2026

As we enter 2026, EPR (Extended Producer Responsibility) regulations continue to reshape how UK businesses approach packaging, recycling and the circular economy.

The regulatory landscape has never been more complex, or more consequential. For producers navigating EPR obligations, the new year isn't just about fresh starts. It's about strategic compliance that protects your bottom line and positions your business for sustainable growth.

The stakes are clear. With an estimated £1.5 billion in annual EPR fees now expected to flow into local authorities, eco-modulated charges rewarding green packaging, and penalties escalating for non-compliance, regulatory compliance has become a competitive differentiator. Businesses that treat EPR as a tick-box exercise face mounting costs and reputational risks. Those that embrace it strategically unlock operational advantages and customer trust.

Here are the essential EPR resolutions every producer should make for 2026 and beyond.

Resolution 1: Master RAM V.1.1 before the February deadline

The Challenge

Your H2 2025 packaging data must be assessed under the Recyclability Assessment Methodology[1], (RAM V.1.1) and submitted by the end of February 2026. For businesses with £2 million+ turnover handling 50+ tonnes of packaging annually this isn't optional. Miss this deadline, and every unassessed item will automatically receive a 'Red' classification.

The financial impact is severe. Red-rated packaging will now be charged at a premium, with base fees increasing annually. Red category materials will attract 1.2x the base fee in 2026/27, and it is already established that fees will rise to 1.6x the base fee in 2027/28 and 2x the base fee by 2028/29.

This system of ‘Eco-modulation’ employs an approach called ‘malus and bonus’.  Packaging assessed as non-recyclable (red) pays an increased fee – the ‘malus’. The additional amounts collected means payments are used to apply a ‘bonus’ to packaging assessed as recyclable – in the form of reduced fees.

So, if your competitors have green-rated packaging whilst yours is rated red they will pay reduced fees, creating a compounding cost disadvantage that subsidises their operations whilst penalising yours.

The Resolution

Conduct your packaging audit this month. Don't wait until February when compliance specialists are overwhelmed and you're rushing to meet the deadline. Early assessment provides time for optimisation and strategic redesign.

RAM V.1.1 evaluates packaging across five stages: classification, collection, sortation, reprocessing and application. Your packaging must meet specific criteria at each stage to avoid automatic Red ratings. Certain features - including integrated electrical components, some substances of very high concern (SVHCs), non-compliant inks and specific PFAS materials – can result in automatic Red classifications across many material types.

However, recent V.1.1 changes have created new opportunities. The removal of retained residue conditions for paper and board packaging, and the elimination of the 40% label coverage restriction for plastic bottles, means previously problematic formats may now achieve better ratings.

For plastic packaging specifically, clear PET bottles can achieve Green ratings, but dark colours (blue, green, brown), problematic additives and multi-material formats remain barriers. The RAM methodology remains stable until January 2027, providing a defined planning window for confident investment in packaging redesign.

The Action

Engage compliance specialists now. Complete assessments in January. Submit reporting by February.

The estimated £1.5 billion annual packaging waste bill for 2026/27 is being redistributed based on recyclability ratings.

Your classification determines whether you're paying in or benefiting.

Resolution 2: Navigate Plastic Packaging Tax changes proactively

The Reality

Plastic Packaging Tax continues to evolve. The current rate is £223.69 per tonne (from April 2025), expected to rise to £228.82 per tonne from April 2026 for packaging with less than 30% recycled content. Whilst a growing proportion of UK plastic packaging now meets the recycled content threshold, significant challenges remain.

The 12-month lookback rule catches many businesses unprepared. You must calculate your 10-tonne registration threshold from the last day of each month, not from 1 April 2022. Even exempt packaging (containing 30%+ recycled content) counts toward this threshold and requires detailed records.

The Challenge

Virgin plastic remains cheaper than recycled alternatives, creating economic pressure against compliance. UK recycling infrastructure faces pressures with major plant closures due to rising costs. For importers, obtaining recycled content certificates from overseas suppliers adds complexity that UK manufacturers don't face.

The Government has also signalled future PPT reforms, including inflation‑linked rate increases and the introduction of mass‑balance rules for chemically recycled content from 2027, and may consult on additional changes such as thresholds or relief structures.

The Resolution

Build robust data collection systems now. Maintain audit-ready records for all plastic packaging—whether taxable or exempt. Establish due diligence procedures with suppliers to verify recycled content claims. For importers, this means developing strong relationships with certified overseas suppliers who can provide reliable documentation.

Evaluate your packaging portfolio strategically. Calculate the tax implications versus the cost of switching to recycled content materials. In many cases, the long-term cost advantages of exempt packaging outweigh the initial investment, particularly as virgin plastic prices remain volatile and regulatory pressure intensifies.

Resolution 3: Prepare for Nation of Sale reporting

The Requirement

Nation of Sale reporting represents a significant data challenge for producers operating across UK markets. For 2026 calendar year data (due April 2027), you must track and report packaging sales by nation - England, Scotland, Wales and Northern Ireland.

This isn't simply about splitting your total packaging tonnage by estimated market share. You need granular data showing where products were actually sold across the four nations.

The Resolution

Plan your data collection systems early. If you're waiting until 2027 to think about Nation of Sale reporting, you're already behind. The systems you implement now will determine the accuracy and efficiency of your reporting in fifteen months.

For businesses with complex distribution networks, e-commerce operations or wholesale channels, this requires careful consideration of data flows. Point-of-sale systems, warehouse management platforms and customer databases all become sources of compliance data.

The Action

Map your current data capabilities against Nation of Sale requirements. Identify gaps. Implement tracking mechanisms that capture nation-level sales data without creating operational burdens. Consider how your existing EPR compliance systems can be enhanced to accommodate this additional reporting layer.

Resolution 4: Get ahead of Textiles EPR

The Opportunity          

While Extended Producer Responsibility (EPR) legislation for textiles hasn't landed in the UK yet, industry consensus indicates textiles EPR is coming within the next five years, with some suggesting that an announcement is likely in 2026 following recommendations from the Circular Economy Taskforce report. For UK clothing producers - manufacturers, importers and retailers, including online sellers - this means the time to prepare is now, not when regulations become mandatory.

For UK businesses selling into Europe, the EU’s revised Waste Framework Directive entered into force last year (October 2025), requiring Member States to transpose textiles EPR into national law by mid-2027 and operate fully functional schemes by April 2028. This creates immediate and concrete obligations for many UK businesses.

The Challenge

Current textile waste capture rates in Europe average just 12%, meaning 88% ends up in mixed municipal waste for landfill or incineration.

EPR will challenge collectors, sorters and recyclers to do much more than this – with the need for both practical and financial support from companies in the fashion and clothing sectors who put textiles on the market.

Producers will pay fees based on volume and environmental impact of products placed on market, with eco-modulation meaning environmentally preferable products attract lower costs. Many expect digital product identifiers, RFID tags and durable QR codes to become reverse supply chain necessities for tracking and data management.

For retailers operating in both UK and EU markets, you're already facing a two-track compliance reality. Some EU obligations are immediate – and all others should be in place by 2028. UK domestic requirements are also coming. Developing integrated systems that serve both markets creates efficiency and competitive advantage.

The Resolution

Check out the current requirements in Europe (Netherlands and France for example) – and keep an eye on future developments in other countries.  UK requirements won’t be exactly the same – but are likely to follow similar themes.

Resolution 5: Master vapes and e-cigarettes compliance

The Urgency

By 31 March 2026, government will set collection and recycling targets for vapes. For e-cigarette producers, this creates specific obligations through compliance schemes that many businesses haven't yet appreciated.

The Opportunity

The regulations are complex and the takeback infrastructure required for vapes presents unique challenges. Battery safety, contamination risks and consumer behaviour patterns all differ from traditional WEEE categories such as fridges and toasters, meaning expertise and experience are essential.

The Resolution

Partner with established expertise. ERP UK has developed growing speciality within the vapes and e-cigarette category, providing expert guidance for producers navigating these complex obligations. ERP UK's specialised vape compliance services provide streamlined processes, comprehensive takeback programmes and data-driven solutions that simplify obligations whilst ensuring full regulatory compliance.

The cost of delay

Across all these EPR obligations, one pattern emerges clearly: early action creates competitive advantage, while delay compounds costs and risks. Businesses that approach compliance reactively face:

• Escalating fees through Red ratings and penalty multipliers
• Rushed implementations that miss optimisation opportunities
• Data gaps that create reporting challenges and potential non-compliance
• Reputational risks as customers and stakeholders verify contributions through public EPR registers
• Operational disruption when regulatory deadlines force urgent changes

Conversely, businesses that embrace EPR strategically unlock:

• Lower fees through Green ratings and optimised packaging design
• Enhanced brand reputation as sustainability leaders
• Operational efficiency through integrated compliance systems
• Stronger supplier relationships built on verified sustainability credentials
• Future-readiness as regulations continue evolving

Your 2026 compliance action plan

Make these resolutions now to help with your EPR compliance:

1. Complete RAM V.1.1 assessments by end of January to avoid February deadline rush and automatic Red ratings
2. Audit Plastic Packaging Tax compliance and implement robust tracking systems for all plastic packaging
3. Design Nation of Sale data collection systems that capture granular sales data across UK nations
4. Prepare for Textiles EPR by getting familiar with requirements in the EU
5. Establish vape compliance partnerships

The regulatory landscape will continue evolving. Battery regulation consultation is expected in 2026 with policy planning signals suggesting implementation from around 2028. As a result, additional EPR categories and tighter requirements are inevitable as the UK builds its circular economy infrastructure.

Businesses that treat these changes as compliance burdens will struggle. Those that recognise them as opportunities for differentiation, efficiency and customer trust will thrive.

Partner with compliance expertise

ERP UK simplifies Extended Producer Responsibility across packaging, WEEE, batteries and emerging categories including textiles and vapes. Our data-driven solutions, comprehensive takeback programmes and specialist expertise help producers to navigate complex regulations whilst optimising costs and building sustainable operations.

Whether you're facing RAM assessment deadlines, Plastic Packaging Tax complexity, Nation of Sale reporting challenges or vape compliance obligations, our team provides the authoritative guidance and practical support you need.

Don't let 2026 become the year of regulatory surprises and penalty invoices. Make compliance your competitive advantage.

Contact ERP UK today to discuss your EPR compliance strategy for 2026 and beyond.

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