Together, the UK, Scottish and Welsh governments, with the Department for Agriculture, Environment, and Rural Affairs (DAERA) in Northern Ireland, are delivering transformative reforms to facilitate sustainable growth across the UK's packaging sector, as an important pillar of our circular economy transition. 

The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, which make packaging producers responsible for the costs incurred by Local Authorities in managing household packaging waste, came into force on 1 January 2025 for all four nations. pEPR plays a central role in achieving our circular economy ambition. Its goals are as follows: 

• Reduce unnecessary packaging and increase the reuse of packaging 
• Incentivise the use of more sustainable packaging materials 
• Invest in local services and infrastructure to improve the quality and quantity of recycled packaging material recovered across the UK 
• Reduce the amount of packaging sent for disposal at landfill and energy from waste 

Extended Producer Responsibility for packaging (pEPR) has been designed to integrate with a suite of interconnected reforms which provide the basis for system-wide change, supporting our broader circular economy ambition for packaging that will include £10bn of investment over the next decade, including: 

• Deposit Return Schemes for drink containers in England, Northern Ireland and Scotland. Strong international evidence shows that deposit schemes reduce litter, increase recycling rates (well-functioning schemes achieve return rates above 90%), and provide high quality recyclate for producers. 
• Plastic Packaging Tax: This aims to create an economic incentive for businesses to use recycled plastic in the manufacture of plastic packaging, thereby creating greater demand for this material. 
• The Emissions Trading Scheme: The UK ETS Authority has announced its intention to expand the scheme to include emissions from waste incineration and energy from waste (EFW) facilities, aiming to drive decarbonisation and sustainable waste management practices, including plastic recycling. 
• Driving improvements to recycling through enhanced statutory requirements for waste collection in each nation. 
• Requiring local authorities in England to collect all six recyclable waste streams (excluding plastic film), from all households by 31 March 2026 via the Simpler Recycling legislation; Plastic Film collection will be mandated from 2027. 
• Improving consistency of recycling service provision to Scottish households through the statutory Code of Practice. The development of the new Code aims to be completed by the end of 2026. 
• An increase in the minimum statutory recycling target to 70% from 2024/25 in Wales and the forthcoming publication of the updated Collections' Blueprint. 

We have collaborated closely with the UK waste management sector, local authorities and the packaging value chain in developing these reforms. The reforms support the circular economy transition by providing the necessary regulatory certainty needed to drive new investment.  

To build on these reforms and respond to concerns raised by producers and other stakeholders, improve the operability of the regulations, and align with international best practice, the UK government notified an amending Statutory Instrument (SI) on 6 May 2025 to the European Union. This will be laid before Parliament in November to come into force ahead of year 2 of the scheme. Amendments include: 

• Enabling the appointment of a producer responsibility organisation (PRO), supporting closer producer involvement in the scheme. This has been a critical request from industry and aligns with international best practice for pEPR to be producer led. 
• Extending closed-loop offsetting provisions to food grade plastic, which will support further our objective to reduce the UK's reliance on virgin plastic material. 
• Minor operability changes to enable more efficient operations. 

1. Producer Responsibility Organisation (PRO)  

In response to requests for greater producer leadership in the operation of the pEPR scheme, the amending regulations will enable the appointment of a Producer Responsibility Organisation (PRO) and will allow the transfer of functions to this new organisation. To prepare for this, alongside the regulations, we are also launching an expression of interest process. This invites potential PRO candidates to register their interest and begin agreeing on the potential role of the PRO with the four governments of the UK.  

Producer Responsibility Organisation Expression of Interest Application which contains eligibility and selection criteria. Interested candidates should submit their completed expression to packaging@defra.gov.uk by 10 June 2025.  

Selected potential candidates will be invited to engage with the four nations to agree on their proposals for the role of the PRO, with this engagement concluding by early September 2025. Following this, PackUK will launch the formal application process in October 2025, with planned appointment of the PRO by March 2026, after the amending regulations come into force. 

2. Offsetting for Closed Loop Recycling Systems  

We have introduced an offset from pEPR household disposal fees for those businesses that operate closed loop recycling systems for food-grade plastics, where materials are collected and recycled by the obligated producer, outside of local authority systems. This change seeks to incentivise producers to establish or continue to deliver closed loop systems that preserve the quality of recyclate and lead to the production of high-quality food grade plastic, in line with our intention to reduce reliance on virgin plastic. 

3. Operability Changes to Enable Effective Scheme Operation 

In addition, the amending SI will bring forward a number of technical changes that will enable more efficient operations. These include: 

• Amending the fibre-based composite (FBC) material definition for pEPR by introducing a threshold to exclude paper and card with plastic content equal to or below 5%.  
• Clarity on how obligations apply to each class of producer obligated by the Regulations, including to give clarity on how obligations are transferred when a company is merged or acquired. 
• Removing barriers to compliance and enforcement: Provides regulators with powers to request information from organisations that are connected to obligated parties and to request data for previous assessment years for historic freeriders so that PackUK can invoice these producers. These changes also update regulator fees to account for new compliance duties. 
• Efficiency and Effectiveness: Minor changes to provide flexibility in the approach to modelling, and more accurately model LA costs for running an efficient waste management service. 
• Minor drafting improvements: resolving potential loopholes and removing ambiguity. 

What is not in scope of the amending statutory instrument (SI)? 

1. Approach to Payments for Littered Packaging 
In response to industry feedback, provisions relating to street binned and littered packaging waste payments are not included in the amending SI to the pEPR regulations at this time. 
There is a shared commitment across the four nations to tackle the scourge of litter in our communities.  
The Deposit Return Scheme for Drinks Containers (DRS), that will go live in October 2027, is a proven model to significantly reduce litter. As a result, the UK Government and DAERA in Northern Ireland will not progress previous plans to extend pEPR payments to cover some of the costs of managing packaging disposed of in local authority street bins or littered on the ground until the scheme is operational and future requirements can then be reviewed.  
The Scottish and Welsh Governments remain committed that pEPR should cover the full net costs of both binned and ground litter cleanup and disposal, and to its introduction in regulations as soon as practicable. 

2. Approach to dual-use packaging  
The pEPR scheme transfers the cost of managing household packaging, once it becomes waste, from local authorities to the producers supplying that packaging. However, some packaging which can be discarded by both consumers and businesses (‘dual-use packaging’) is currently captured by the household packaging definition, as it is difficult to track or evidence where it will be discarded when first supplied by a producer, particularly when supplied through a wholesaler.  
We have considered international examples tackling this issue: there is no established method, that meets the expectation of UK businesses, to exempt this packaging from pEPR fees. For example, overseas schemes typically use size or volume to determine if packaging should be reported as household or non-household. Industry has raised concerns that this will not work effectively for many UK business models. Alternatively, some countries have tried allowing individual producers to report where they anticipate their packaging is being discarded, on a product-by-product basis. This creates increased complexity and enforcement costs and has subsequently resulted in excessively high fees for any packaging remaining in the scheme.  
We recognise the concerns of affected businesses, and that some businesses have put forward potential approaches. We will work with these businesses to explore their proposals at pace, including considering whether they would require regulatory amendments. We will soon begin a series of co-design activities with key stakeholders to work up detailed proposals and, where a workable solution can be found and subject to ministerial agreement, we will look to introduce these following a formal consultation. 

3. Reporting Requirements  
We have also heard clear feedback from obligated producers around the time and resource requirements to assess packaging for recyclability and upload this data into the reporting system. This particularly impacted producers with mixed large packaging portfolios. To address these concerns, we are working with compliance schemes and producers on options to reduce the reporting burden. We will share further details very soon. 

4. Supporting and growing the UK’s existing recycling infrastructure  
The UK’s plastics reprocessing sector has been struggling over recent years. The four nations will therefore work in partnership to bring forward a programme of work to support its stability and growth. This includes:  

• Strengthening of the Plastics Packaging Tax: To support use of and investment in advanced chemical recycling technologies, at Autumn Budget 2024 the government confirmed it would allow a mass balance approach for chemically recycled plastic, for the purposes of the PPT. To give clarity and certainty, the government has confirmed it intends to implement this change from April 2027 and commence the legislative process in the Finance Bill 25/26. Pre-consumer waste will also no longer be accepted as a source of recycled plastic for PPT from the same date.  
• Reforming of the Packaging Recovery Note (PRN) system: Over the course of 2025, we will work with the value chain on reforms to the PRN system with the aim of levelling the playing field between domestic re-processors and exporters of waste. We will look at measures to stabilise the PRN market, reduce price volatility and reduce exporting of plastic waste.  
• Food Grade Plastics: The Food Standards Agency has recently confirmed it will now act as the competent authority for food grade plastics, which will enable continued investments in reprocessing infrastructure and support businesses to meet European obligations for minimum recycled content by 2030. 

5. Improving Efficiency & Effectiveness of Local Authority Packaging Services 
There are some high performing local authority packaging collection and recycling services across the UK, most notably in Wales, and in some other parts of the UK including South Oxfordshire, Three Rivers District Council, Stratford-upon-Avon, Antrim & Newtownabbey, Scottish Borders and North Ayrshire. However, there is widespread room for improvement.  
The current arrangements will put in place a range of measures to drive improved performance and ensure the efficiency and effectiveness of the services provided. These include:  

• Introducing an Improvement Action Process (IAP), through which the poorest performing local authorities are supported to deliver better recycling outcomes. PackUK – the pEPR Scheme Administrator - will run an IAP pilot in the summer of 2025.  
• Using financial disincentives to respond to continued poor performance: for example, PackUK has the power to make deductions of up to 20% of pEPR payment where local authorities continue to fail to provide an effective waste management service and are not doing what they could reasonably be expected to do to improve their service. This deduction will be applied to the assessment year following such a determination. 
• Requiring local authorities in England to collect all six recyclable waste streams (excluding plastic film), from all households by 31 March 2026 via the Simpler Recycling legislation; Plastic Film collection will be mandated from 2027. 
• Improving consistency of recycling service provision to Scottish households through the statutory Code of Practice. The development of the new Code aims to be completed by the end of 2026. 
• An increase in the minimum statutory recycling target to 70% from 2024/25 in Wales and the forthcoming publication of the updated Collections’ Blueprint. 
• In Northern Ireland the Waste and Contaminated Land (Northern Ireland) Order 1997 includes the target for 65% of municipal waste prepared for re-use and recycled by 2035. 

The four nations of the UK will therefore consider further measures to support and incentivise improved efficiency and effectiveness of local authority services to manage packaging waste. This will focus on how we ensure that investment through pEPR supports local authorities to deliver improved outcomes and value for money.

We will work with local government and businesses, the PackUK Efficiency and Effectiveness Technical Advisory Committee to develop these proposals. We will establish opportunities through the financial and broader policy levers of pEPR to better incentivise Local Authorities (LAs) to: 

• Collect and sort higher quantities and quality of materials for recycling. 
• Reduce costs to efficient levels whilst securing these outcomes. 

We have heard industry feedback and recognise interventions may be required to further refine pEPR. 

Updates covering England, Scotland and Northern Ireland 

While we continue to work in close partnership with all four nations of the UK in the implementation of pEPR, this is a devolved policy competence and there are several areas that each nation will progress either collaboratively or individually in addition to the improvements set out above. 

Deposit Return Scheme for Drink Containers 

UK Deposit Management Organisation Limited (UK DMO) has been announced as operator of the Deposit Return Scheme (DRS) for single-use plastic and metal drinks containers across England, Northern Ireland and Scotland. The appointment has been made by the UK Government and DAERA, effective from 2nd May 2025. In Scotland, Scottish Ministers have decided that UK DMO should be designated as the DRS scheme 6 administrator and a Designation Order is subject to approval by the Scottish Parliament. UK DMO is a business-led, not for profit organisation.  

The Deposit Return Scheme in England, Northern Ireland and Scotland will launch in October 2027, which will drive our efforts to stop litter filling up our streets, rivers and oceans.  

We will continue to work closely across the sector, and now with UK DMO, to ensure the smooth implementation of the DRS for businesses and consumers and to resolve any issues as they arise. We will also maintain regular one to one engagement with retailers, producers and interested groups to monitor progress towards rollout.  

UK DMO will now begin engaging with partners, business, including retailers and drinks producers consumer and environmental groups to design and operate the scheme.

The Welsh Government is developing a DRS to suit its context in which already high levels of recycling are being achieved. 

Supporting Glass Reuse 

Reuse has a significant role to play in moving to a circular economy. The pEPR Regulations already create incentives for businesses to consider reuse: producers are only required to report and pay household disposal cost fees for reusable packaging the first time it is placed on the market. Additionally, at the end of its life, reusable packaging can be offset against household disposal cost fees if they are sent for recycling by the producer. 

A producer with a high performing reuse system can therefore avoid the majority of the disposal costs resulting from the pEPR Regulations. 

As part of the circular economy transition, Defra will do more to support industry to increase reuse and refill, with a particular focus on glass as a highly reusable material. This is an important part of how we support the future of the UK glass industry in the context of pEPR. 

Initially, following engagement with industry, Defra will focus policy development on on-trade glass bottle reuse. Glass reuse has the potential to support significant emission reductions and industry is already making significant progress in 7 this area with a range of schemes and trials that are already in place or being planned. Defra intends to continue discussions with the sector and support transition towards glass reuse. In the autumn, we will launch a call for evidence focusing on measures to support and incentivise reuse.  

The Welsh Government is seeking to achieve widespread reuse of glass in its development of a DRS for Wales. 

Updates covering England only 

A Circular Economy Finance Coalition  

To capitalise on the regulatory certainty provided by pEPR, combined with Simpler Recycling and the Deposit Return Scheme for Drinks Containers, we are committed to work with the finance sector and other jurisdictions to boost investment in the transition to a circular economy. 

Together with the Dutch government and the Lord Mayor of London, Defra has established a Circular Economy Finance Coalition. This will explore ways to boost investment in critical infrastructure and technologies. We will map and quantify finance gaps and investment opportunities; and hand-in-hand with the international finance sector, we will develop practical steps to help generate investment in the Circular Economy. 

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