What is Packaging Extended Producer Responsibility policy – and why does it matter?
Sustainability and packaging design are now central priorities for the luxury sector, with growing pressure to demonstrate authenticity, responsibility, and transparency. As pEPR increases both financial and environmental expectations, luxury brands must balance aesthetics with circularity, creating packaging that is not only a beautiful extension of the product, but also recyclable, lightweight, and materially efficient. These choices can reduce modulated fee liabilities, strengthen brand reputation, and future-proof product lines in a market where sustainability is becoming a defining marker of luxury.
2024 ushered in changes to the reporting and financial obligations of producers who handle packaging in the UK. The new Extended Producer Responsibility (EPR) system passes the full financial costs associated with the collection, sortation and recycling of packaging on to the companies who are responsible for putting that packaging on the market. The new regulations also create a comprehensive and adaptable framework that incentivises recyclable packaging, waste reduction, future labelling requirements, and improved data gathering up and down the supply chain.
Affecting businesses with a minimum turnover of £1m and responsible for more than 25 tonnes of packaging in a calendar year, pEPR has brought a large number of businesses into the legislation; some for the first time.
The past couple of years have brought huge upheaval to the packaging sector with a vast increase in the amount and granularity of data required by producers from across the supply chain, increased bi-annual reporting, introduction of the RAM (Recycling Assessment Methodology) and increased costs. But the dust is finally settling, with two full years of reporting complete.
That is not to say that the next couple of years aren’t full of changes and challenges for producers. Development of the RAM and the effect of modulated fees based on those recyclability assessments will be one of the big levers for change. The key milestones and upcoming changes are outlined in the RAM Roadmap to 2026.
Below, is a timeline of major events for the coming year under some key headings starting with pEPR, fees, and the related Deposit Return System (DRS) regulations. This is followed by a general overview of the wider circular economy and waste collection reforms.
Timeline for the coming year
Packaging EPR Updates
1st January 2026: Amended pEPR came into force.
March 2026 – PackUK will appoint the Producer Responsibility Organisation (PRO).
July 2026: RAM 2027 expected to be released.
Summer 2026: Potential update on mandatory labelling.
November 2026: Potential future regulatory amendments to be debated in parliament.
Reporting Schedule
1st January 2026 onwards – Producers will need to start gathering Self-managed Organisation Waste data and Nation of Sale data for reporting by 1st August 2026 and 1st April 2027 respectively.
1st January 2026 onwards – Producers will need to start gathering data on plastic and paper carrier bags they have supplied in England for reporting by 1st April 2027.
1st April 2026 (deadline) - Large producers must report Jul-Dec 2025 packaging data, small producers must report annual 2025 packaging data, including a report on carrier bags suppled in England in 2025.
1st August 2026 (deadline) – Large producers must register and report their Jan-Jun 2026 packaging data, including mandatory self-managed organisation waste data.
Deadlines might be earlier if your business is registered with a compliance scheme.
Fees
14th October 2025 – Year 1 Notice of Liability (NoL) sent to relevant producers
3rd December 2025 (deadline) – Deadline for first payment of NoL
December 2025 – Illustrative 2026 base fees (inc. modulation)
24th February 2026 – Government stepped in to cover £63m funding shortfall
o NoL sent out last Oct will not increase, unless you have completed a resubmission.
March 2026 – PackUK will reissue Year 1 NoL where relevant
June 2026 – 2026 base fees published
June 2026 – 2026 NoL to be issued
December 2026 – Illustrative 2027 base fees (with separate fees for rigid and flexible plastic)
Producers still also have a PRN obligation alongside their Notices of Liability. PRNs will usually be procured by the compliance scheme if your business is registered with one. or will have to be self-fulfilled if registered directly with the appropriate authority.
Deposit Return Schemes (DRS)
The UK Deposit Management Organisation (UK DMO) (rebranded to Exchange for Change) hosted introductory webinars throughout March. They will be hosting further webinars throughout 2026 as further information is released, such as labelling, fees, deposit information, and other requirements for businesses in the UK
As they move from the ‘set-up phase’ into the ‘delivery phase’ we are expecting publication of the Operation Plan in May 2026 to lead us up to go-live in October 2027.
Circular Economy
31st January 2026: Circular Economy Strategy (Scotland) consultation closes.
2nd February 2026 – Northern Ireland consults on their Resources and Waste Management Strategy
‘Spring’ 2026 – Circular Economy ’Growth Plan’ (England) to be published
Sustainability Reporting Standards (SRS)
‘25th February 2026 – The UK’s sustainability reporting standards S1 and S2 have been published for voluntary use
The FCA is currently consulting on mandating SRS for listed and large companies in the UK
Simpler Recycling
31st March 2026 – Households in England will have to separate recycling (ex. flexible plastics) and collect waste food for Simpler Recycling (SR) Year 2
‘End’ 2026 – Scotland are co-designing a new ‘Code of Practice for Household Waste Recycling’, which might lead to similar policies as SR in England, with an aim to release this as a consultation end 2026.
Beyondly works closely with producers to help them navigate individual responsibilities around pEPR and sustainability. If you wish to discuss your requirements with a member of the Beyondly team, please email [email protected] or find out more on their website here.
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