Packaging EPR Deadline 2026: What Producers Need to Know

Defra has confirmed that the deadline for resubmitting 2025 packaging data under the Packaging Extended Producer Responsibility (pEPR) scheme will be brought forward to 1 September 2026. The change affects when Notices of Liability (NOLs) for 2026/27 will be issued, and in turn, when producers will receive their first quarterly payment requests. For businesses already navigating a complex compliance landscape, this is an important development to understand and plan for now.

Why the deadline is changing

The decision follows a funding shortfall in the pEPR scheme for 2025/26, which Defra had to step in to cover. Ministers have been clear that this cannot happen again. The revised timetable is designed to give regulators enough time to validate producer data before NOLs are issued, reducing the risk of significant recalculations further down the line.

PackUK, the scheme administrator, has also confirmed that indicative base fees will not be updated ahead of the NOL. Rather than continuing to publish figures that may shift, the intention is for the NOL itself to effectively confirm the numbers. This reflects a broader aim for 2026/27: greater stability, improved accuracy and fewer large cash movements within the system.

It is worth understanding the scale of the resubmission challenge. Around 80% of audits result in a resubmission. This means the validation process takes time, and the new deadline is designed to accommodate that properly.

What this means for producers

The practical consequence of the revised timetable is a later-than-usual NOL. With the resubmission deadline set for 1 September 2026, NOLs for 2026/27 are not expected to be issued until six to eight weeks after that date closes, placing them in late November 2026 at the earliest. First quarterly payments would then follow approximately 50 days after issue, meaning mid-January 2027 is the likely start point for payment obligations.

For producers, this creates a real planning challenge. Businesses that are used to building compliance costs into annual budgets will have less certainty about their final obligations until later in the year than they might expect. Indicative figures will still be available and can provide a steer, but they remain just that – indicative - until the NOL is issued.

It is also worth noting that resubmissions will continue to affect recycling obligations, including PRN (Packaging Recovery Note) requirements. Producers should factor this into their wider compliance planning, not just their financial forecasting.

What the experts are saying

John Redmayne, MD at ERP UK, has responded to PackUK's announcement introducing a 1 September deadline for producers to resubmit their 2025 packaging data.

"PackUK's decision to extend the 2025 packaging data resubmission deadline should help to ensure that Notices of Liability are based on the most accurate producer data available. Following last year's funding shortfall, improving confidence in the final figures is undoubtedly a positive step for the system as a whole.

"That said, it does create a new challenge. Delaying the issue of confirmed fees and Notices of Liability means that producers will have less certainty around their financial obligations until later in the year, making budgeting and financial planning more difficult. While previously published illustrative fees may still provide a useful guide, they are simply estimates, meaning businesses will need to plan with a greater degree of uncertainty.

"This makes it more important than ever that producers engage with their compliance scheme early. Understanding the implications of the revised timetable, reviewing illustrative fees as they become available and building flexibility into compliance planning will help businesses avoid surprises later in the year.

"At ERP UK, we'll continue working closely with producers to help them understand what these changes mean in practice, provide guidance as further information becomes available and support them in planning for their obligations with as much confidence as possible."

A system still finding its footing

It is important to keep this change in context. This revised timetable is not intended to be the permanent approach. Defra has signaled that amendments to regulations are expected in future years, which will enable different approaches and timelines as the system matures. What we are seeing now is a pragmatic response for year 2 to the challenges of year one, not a settled long-term model.

Late registrations will also be handled within this framework. A late registration will result in a new NOL being issued, with a reconciliation of numbers to follow at a later point. Producers who are not yet registered should treat this as an additional reason to act promptly.

How to navigate the uncertainty

There is no single action that removes the planning uncertainty created by a later NOL. But there are steps producers can take to manage it sensibly.

• Engage with your compliance scheme early. The sooner you are in conversation with your scheme, the better placed you will be to understand the likely shape of your obligations. Waiting for the NOL before starting that conversation is too late.
• Use indicative figures as a planning tool. They are not confirmed numbers, but they are not meaningless either. Build them into your financial modelling with appropriate headroom, and revisit them as updated information becomes available.
• Build flexibility into your compliance planning. This year, more than most, businesses need to avoid locking in assumptions about compliance costs too early. A degree of financial flexibility will make it easier to absorb any variance between indicative and confirmed figures.
• Keep an eye on your PRN position. Because resubmissions affect recycling obligations as well as fees, your PRN strategy may need to be reviewed alongside your data submissions. Do not treat these as separate workstreams.

The new Packaging EPR Deadline 2026 leaves producers with less time to correct data, more uncertainty around final fees and a narrower window to plan for compliance costs. Getting your packaging data right now could be the difference between accurate Notices of Liability and unexpected financial pressures later in the year.

ERP UK supports more than 700 businesses with packaging compliance, helping producers navigate changing regulations, improve data accuracy and prepare for Packaging EPR obligations with confidence. Our experts can help you understand the impact of the revised timetable, review your reporting processes and develop a compliance strategy that reduces risk and avoids costly surprises.

Speak to the Packaging EPR Experts

Whether you're unsure how the new deadline affects your business, need support with packaging data submissions or want guidance on budgeting for future Packaging EPR fees, our team is here to help.

Talk to ERP UK today and get ahead of your Packaging EPR obligations before the 1 September deadline.

• Contact our team: Contact ERP UK
• Learn more about Packaging EPR: Packaging EPR Services

About ERP UK

ERP UK is one of the UK's leading environmental compliance schemes and part of the global Landbell Group. We help businesses simplify Packaging EPR, WEEE, batteries and producer responsibility obligations through expert guidance, robust data management and practical compliance support. With over 700 members and decades of compliance experience, we're helping producers turn complex regulations into manageable business processes.