Packaging EPR - A Guide to Labelling 

Central to the successful delivery of EPR is the requirement to use labels to indicate whether packaging is or is not recyclable. The following article, accompanied by a set of useful Q&A’s, will support stakeholders as they work to deliver on their labelling obligations. 

A popular approach 

The EPR labelling proposals that were set out in the 2019 and the 2021 consultations on Packaging Producer Responsibility received widespread support, with 90% of respondents favouring our proposals for a binary labelling system. The government’s response to the EPR consultation, which was published in early 2022, confirmed our intention to proceed with a requirement to label packaging to indicate if it is, or is not, recyclable. 

Consequently, all primary and shipment packaging will need to be labelled as ‘recycle’ or ‘do not recycle’, along with the accompanying logo, so that when an individual or entity disposes of packaging, there will always be a clear instruction relayed as to how to proceed. 

Single UK wide solution 

There was widespread support at the 2021 consultation for a single UK wide approach to labelling. To deliver this inclusive approach, we have agreed with WRAP, the Waste and Resources Action Programme, that the ‘recycle now’ mark, or the ‘Swoosh’ that it tends to be referred to, will be used as the logo to be applied to packaging. 

Producer labelling obligations 

We want to capture those that have the most influence over packaging design. Therefore, those obligated to label will be brand owners (and where there is no brand owner, pack-fillers) and importers. In the main, these categories align with those required to report data and pay disposal cost fees.  

Distributors (i.e. manufacturers or importers) that supply unfilled plain packaging will be required to provide small businesses with information on the recyclability of this packaging. This is to make it easier and less burdensome for small businesses to fulfil their labelling obligations. 

Some flexibility will be given to small businesses in how they provide consumers with information on how to dispose of packaging correctly. 

Who is obligated to label? 

• Brand Owners: Businesses who either put goods into packaging, or have goods put into packaging, and place those goods on the UK market under their brand name (and where no brand owner the packer/filler)​ 
• Importers: Businesses who are responsible for the import of filled packaging into the UK for sale​ 
• In addition, distributors (of unfilled, plain packaging) will be required to provide small businesses with information on the recyclability of the packaging they supply, and some flexibility in how they provide recycling information will be provided to users of this packaging 

Timeline 

The requirement to label packaging will be introduced as a part of our new UK wide packaging and packaging waste statutory instrument (SI) which we expect to come later this year.  

There will be two key dates for labelling requirements.  

1. The first is 31 March 2026, when we want labelling to be in place for all materials (except plastic films and flexible packaging).  
2. The deadline for labelling plastic films and flexible packaging will be the 31 March 2027. This is the point at which full binary labelling will be in place.  

These dates align with our proposals to require local authorities and businesses to have recycling collections in place for recyclable films and flexibles. 

Key information 

• The SI will set out the key labelling requirements, including the requirement to assess packaging to determine recyclability and minimum size requirements.  
• Labelling guidance will be published to help businesses adopt the requirements. This will include advice regarding the use of colour, labelling of multi-material packaging and the inclusion of additional information on where to recycle where there are alternative collection methods, such as take to store. 

Recyclability assessment  

To ensure consistency in the approach, so the correct label is applied, there will be a requirement to assess packaging using a prescribed methodology. Whist it may be the case that the majority of packaging will be straightforward to assess, we also recognise that some packaging items will require a more comprehensive assessment.  The Scheme Administrator will, when in place, have ownership of the methodology, however, to allow sufficient time for businesses to undertake assessments, Defra will procure this methodology in advance of the SA being appointed. A tender will be issued shortly.  

We welcome suggestions from any impacted stakeholders on specific labelling guidance they would like published. Please click here to complete a quick survey.

Questions & Answers

​​​Question We're looking to add OPRL on our packs; will they need to be changed to simply ‘recycle’ or ‘do not recycle’. 

Answer The regulations will require the application of a logo and the words recycle or do not recycle and additional advice will be provided in guidance. We understand that OPRL has already adopted ‘Do not recycle’. Producers can choose whether to manage the application themselves or sign up to a scheme such as OPRL. 

Question Is there flexibility for small businesses and how they communicate to their customers regarding labelling?  

Answer Yes, we've had a lot of discussion with sector representatives around how small businesses label - particularly those that purchase unbranded and plain packaging. The regulations will include several options to make it more flexible for smaller businesses  

Question In line with the new recycling labelling, is there any further indication of when the consistent collections consultation response will be published?  

Answer We are conscious that there is interest in our response to the consistent collections consultation that will set out what local authorities will be required to collect for recycling. We are aiming to get this published as quickly as we can. We are continuing to work through all necessary clearances required to publish this response.  

Question Will the use of the label be free of charge in the same way that producers don't pay a license fee to use the crossed out ‘Wheely bin’ logo.  

Answer Yes, it is free of charge.  

Question What happens if a product has multi component primary packaging where some can be recycled and some can't? For example, a glass jar with a lid that can't be recycled. 

Answer In relation to multi component packaging, every single component of packaging does not need to be labelled separately, but somewhere on the packaging, (in this instance, possibly on the label around the glass jar), we would expect information to be provided on the different packaging components to indicate whether they can be recycled or not recycled. Further advice regarding labelling of multi component packaging will be included in the guidance.  

Question When will the labelling guidance be available?  

Answer We are in the process of working up this guidance. Once we have produced a draft, we will engage with stakeholders before publishing the final version. The plan is that this guidance will be available later this year.