UK packaging EPR compliance guide for 2026

Introduction

UK packaging EPR compliance guide for 2026: Packaging EPR is a regulatory landscape that doesn't stand still. Rules change, deadlines shift and the financial stakes keep rising. Staying on top of it all, and understanding what's actually required of your business right now, isn't always straightforward.

This guide, written in April 2026, aims to cut through the noise. It covers the current state of the scheme, including the shift to modulated fees, the latest RAM developments and what both small and large producers need to do to stay compliant.

Whether you work in product design, procurement, sustainability or compliance, this is your practical starting point for UK packaging EPR compliance in 2026.

What is packaging EPR?

Extended Producer Responsibility (EPR) for packaging is a policy that makes businesses financially responsible for the packaging they place on the UK market,  from production through to disposal.

It replaces the old Producer Responsibility Obligations system and is designed to shift the cost of managing packaging waste away from local authorities and taxpayers, and onto the businesses that create that waste in the first place. The goal is a more circular economy: one where packaging is designed with its end of life in mind.

In practice, this means that if your business supplies packaged goods in the UK, whether you manufacture, import, fill or brand that packaging, you likely have obligations under pEPR.

Are you an obligated packaging ‘producer’?

You're classed as an obligated producer if your business:

• Has an annual UK turnover of £1 million or more
• Is responsible for more than 25 tonnes of packaging placed on the UK market in the previous calendar year
• Carries out one or more packaging activities

Packaging activities include supplying packaged goods under your own brand, placing goods into packaging, importing products in packaging, owning an online marketplace, or supplying empty packaging.

UK packaging EPR compliance: What are your obligations?

Your responsibilities depend on whether you're classified as a small or large producer:

• Small producers have a turnover of £1-2 million and handle more than 25 tonnes of packaging, or have a turnover above £1 million and handle between 25 and 50 tonnes.
• Large producers have a turnover of £2 million or more and handle more than 50 tonnes of packaging.

If your business is part of a UK group of companies, obligations apply to the group as a whole via the common parent or holding company.

Large packaging producers must:

• Register with the appropriate environmental regulator (such as the Environment Agency in England) directly or through a compliance scheme
• Report packaging data every six months (January-June and July-December)
• Pay waste management fees to cover the cost of collecting and recycling household packaging
• Obtain Packaging Waste Recovery Notes (PRNs) or Packaging Export Recovery Notes (PERNs) to meet recycling targets
• Pay scheme administrator and regulator charges
• Submit nation data showing where in the UK packaging is supplied or discarded

 Small packaging producers must:

• Register with the appropriate regulator
• Report packaging data annually (by 1 April for the previous year's data)
• Pay a registration fee

Small producers are not currently required to pay EPR waste management fees or obtain PRNs, though this may change as the scheme matures.

For both producer types, the data to be reported must cover packaging material (plastic, glass, aluminium, steel, paper/card, wood), packaging type (household vs non-household), packaging class (primary, secondary, shipment or tertiary) and weight.

The pEPR timeline: where are we now?

No UK packaging EPR compliance guide for 2026 would be complete without some key dates to show how far we’ve come, and what lies ahead.

 Here's a clear, up-to-date picture of how the scheme has developed and where it stands in April 2026.

• 2023-2024 — Data collection begins Businesses started collecting and reporting packaging data. Data gathered for 2024 was used to calculate the first EPR fees.
• 2025 — Full base fees introduced Flat-rate EPR waste management fees for household packaging came into effect. The first invoices (referred to as ‘Notices of Liability’) landed from October 2025, with fees calculated on 2024 packaging tonnages reported by producers and local authority waste management costs. Nearly all fees came in lower than December 2024 estimates, with glass fees reduced by around 20%.
• 1 April 2026 — Key reporting deadline Small producers submitted their 2025 packaging data. Large producers submitted their H2 2025 data, including separate figures for flexible and rigid plastics.
• April 2026 onwards — Modulated fees take effect This is a significant shift. From the 2026-2027 scheme year, fees are no longer flat rate. They're now modulated based on the recyclability of your packaging. The first invoices reflecting modulation are expected in the second half of 2026.
• 1 April 2027 — Nation of sale data deadline Producers must report data on where in the UK packaging is supplied.
• 2027 — Consumer labelling Mandatory unified "Recycle / Do Not Recycle" labelling remains a key industry target for 2027, though the mandatory provision was temporarily removed from the main pEPR Statutory Instrument in late 2024 to avoid implementation delays. Businesses should continue preparing for this requirement.
• 2028 — Deposit Return Scheme trigger If the Deposit Return Scheme is not operational by 2028, drinks container producers (PET plastic, aluminium and steel) will become subject to pEPR obligations.

Modulated fees: what's changing and why it matters

The introduction of modulated fees is one of the most commercially significant developments in the pEPR scheme to date.

Under the base fee structure, all producers paid a flat rate per tonne of packaging material. From 2026, that changes. Fees are now adjusted based on how recyclable your packaging actually is — using a system called the Recyclability Assessment Methodology, or RAM.

The modulation framework works on an escalating scale:

• 2026-2027: Red-rated (hard-to-recycle) packaging pays 1.2x the base fee; Green-rated (highly recyclable) packaging pays less
• 2027-2028: The multiplier rises to 1.6x for Red-rated packaging
• 2028-2029: Red-rated packaging faces fees at 2.0x the base rate

Businesses that continue using hard-to-recycle materials will face a growing financial penalty. Those that invest in recyclable packaging design now will benefit from lower fees over time.

RAM: the recyclability framework behind the fees

RAM – which stands for the Recyclability Assessment Methodology - is the system PackUK uses to rate packaging recyclability. Ratings fall into three categories: Green (highly recyclable), Amber (recyclable with limitations) and Red (not currently recyclable at scale).

These ratings are based on real-world waste facility data, not theoretical recyclability. A material might be technically recyclable but still receive a Red rating if the infrastructure to collect and process it at scale doesn't yet exist in the UK.

RAM is not static. PackUK has published a roadmap through to 2030, with annual updates planned and technical reviews covering areas including rigid plastics guidance, printing inks, fibre-based composites and food contamination. Bioplastics and compostables are under review for potential inclusion from 2029.

For a detailed breakdown of the RAM roadmap and what it means for your packaging strategy, read our guide.

What is PackUK?

 PackUK is the Scheme Administrator responsible for implementing the pEPR scheme across the 4 nations in the UK. It sets the strategic direction for how fees are calculated, how RAM ratings are developed and how the scheme evolves over time.

PackUK published its interim strategy in 2025, with a long-term strategy to follow. It operates on the principles of 'polluter pays' and it actively engages with industry through its Scheme Administrator Steering Group and various technical advisory bodies.

How ERP UK can help packaging producers

 Navigating pEPR is complex. The data requirements are detailed, the deadlines are strict and the financial implications of getting it wrong - or simply not optimising your packaging mix - can be significant.

ERP UK is a leading compliance scheme with over 700 businesses already on board. As part of the global Landbell Group, ERP UK brings both local expertise and international reach to packaging EPR compliance.

Working with ERP UK, you get:

• Complete management of registration and data reporting
• Support with PRN and PERN procurement
• Access to the Circul8 online reporting platform for streamlined data submission
• Regular regulatory updates as the scheme evolves
• Named account managers and direct access to UK compliance experts
• Data collection support and packaging audit guidance
• Green Dot licensing and take-back programme access

Whether you're a small producer getting to grips with your first annual report or a large producer managing complex multi-material packaging portfolios, ERP UK can simplify the process and help you stay ahead of regulatory change.

UK packaging EPR compliance: Why it’s worth getting it right

The shift to a circular economy is a direction of travel that makes sense for businesses, communities and the planet.

EPR for packaging is one of the most meaningful levers available to drive genuine change in how materials are used, recovered and reused. The businesses that engage with it seriously, not just as a compliance exercise but as a design and procurement challenge, will be better placed to meet future regulations, reduce costs over time and demonstrate real environmental leadership.

The goal of circularity is a worthy one. ERP UK is here to help you get there.

Find out how ERP UK can support your UK packaging EPR compliance requirements here.

Disclaimer: Regulations are subject to change. Always consult official GOV.UK guidance or speak to a compliance scheme for advice tailored to your business.

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