The aim of pEPR is to encourage designing for recyclability, and at Veolia, we’re here to help keep you informed on this evolving legislation and help you understand the life cycle of your packaging.
What is Packaging Extended Producer Responsibility (pEPR)?
The UK’s pEPR scheme is transforming how packaging waste is managed. Under the new rules, producers will bear the cost of disposing of and recycling packaging.
The pEPR scheme requires packaging producers to pay a “waste disposal fee” for all in-scope household packaging placed on the market.
This represents a significant shift, taking the responsibility away from Local Authorities (LAs) and placing it onto the producers themselves, with the waste fee used to create a fund to cover the costs of collection, sorting and recycling of household packaging waste.
Producers are also required to report data on the amount and type of packaging they supply on the market (either directly or imported).
Current Implementation Timeline
The scheme went live in January 2025, with calculations based on data supplied by obligated producers in 2024.
You will be classed as an obligated producer if:
- You are a business, subsidiary, or group (but not a charity),
- With a UK annual turnover of £1 million or more,
- And are responsible for importing or supplying more than 25 tonnes of packaging to the UK marker per year.
Local authorities (LAs) are due to receive the first half of their Year 1 payments in November 2025, and the remaining installments in early 2026 (January and March respectively).
Payment Adjustments & Quarters
The modulation policy has been confirmed. This is a three-year structure designed to escalate or subsidise producer fees pertaining to the methodology underpinning the RAM (Recyclability Assessment Methodology).
Year 1 - 2025–26 - uses existing public data and sampled local authority information for modelling.
Future years - from 2026–27 - incorporates actual data reported via the Local Authority Portal (LAP) plus:
- Modulation enabled (penalising low-recyclability packaging)
- Effectiveness assessments - poor-performing LAs may face up to 20% payment reduction
It is essential to note that local authorities in England will only receive pEPR funds that are spent on household packaging waste management and recycling (this will include some requirements to report spending to Pack UK).
Producer Invoicing Process
- Base fees for producers are calculated using:
- Total LA costs from Local Authority Packaging Cost and Performance Model (aka LAPCAP)
- Scheme administrator fees
- Communication and debt costs.
- Fees are invoiced annually in early summer, based on packaging tonnage data reported by producers.
- From Year 2 (2026–27) producer invoices will reflect:
- Modulated fees based on recyclability
- Adjustments based on actual LA costs and performance metrics.
Base Fees
Defra published the long awaited base fees last month in June 2025, following three previous sets of illustrative base fee publications in August, September and December 2024. The confirmed base fees have seen a reduction in values across every material category, aside from fibre-based composites.
Leading on the Delivery of pEPR
Pack UK
PackUK, has been announced as the Scheme Administrator for the delivery of pEPR, effectively launched on 21st January 2025. Its interim strategy can be found here.
Essentially, Pack UK will be responsible for:
- Setting disposal fees payable by producers supplying household packaging,
- Invoicing liable producers,
- Transferring monies from producers to Local Authorities,
- Undertaking public information services and campaigns,
- Developing and publishing the Recyclability Assessment Methodology (RAM) and accompanying guidance.
PackUK will appoint a Producer Responsibility Organisation (PRO) to carry out several key functions on its behalf. While the PRO will develop its own strategy, it will remain closely aligned with the strategic direction of PackUK.
Producer Responsibility Organisation (PRO)
The deadline for Expressions of Interests, for invited PRO candidates to agree the role of the PRO with the four nation governments, concluded on 10 June 2025, with the full application opening in October 2025. The view is for an appointment of the official PRO in “early 2026”, once the new regulations come into force.
Technical Advisory Committees
A number of Technical Advisory Committees (TAC’s) have also been established, to support the design and delivery of core pEPR policy frameworks:
- Communications and Behaviour Change TAC,
- Efficient and Effective TAC,
- RAM TAC.
Understanding the Recyclability Assessment Methodology (RAM)
The Recyclability Assessment Methodology (RAM) is designed to ensure pEPR lives up to its intended purpose to:
- Standardise the approach to assessing the recyclability of packaging
- Encourage producers to design with recyclability in mind
- Support the UK's commitment to delivering a circular economy
- Help reduce the environmental impact of packaging waste
The RAM requires large producers to assess and report on the recyclability of their packaging.
A red/amber/green tiered system is intended to inform the level of fee modulation payable for each material from year two of pEPR: for example, a green recyclability score would result in a lower pEPR fee.
CIRCPACK, Veolia’s own packaging consultancy team, who supports brand owners and packaging manufacturers to assess and improve the recyclability of their packaging for the EU27+3 market, are able to carry out these assessments on your behalf.
Some additional pEPR amendments and policy updates:
- Defra has formally launched six Local Authority “Improvement Action Plan” (IAP) pilots - 1 in Northern Ireland, 2 in Scotland and 3 in England - to support the work in formulating the framework and process for IAP’s issued to “poorly performing” Local Authorities, based on how they are rated against “Efficiency and Effectiveness” pertaining to their recycling services under pEPR. The Pilot for Wales is being developed with the Welsh government. Defra is due to release guidance regarding the methodology underpinning “Efficiency and Effectiveness” ratings in due course.
- Offsetting for Closed Loop Recycling Systems, for businesses which collect and recycle their own materials to the same food-grade plastic.
- Proposals regarding “dual-use” packaging; whereby claims could be evidenced for packaging that does not enter household kerbside waste and will be self-managed commercially. Please note that a series of sector-specific workshops have been planned by Defra, to evaluate proposals.
- Provisions to support glass re-use and re-fill, with an initial focus on on-trade glass bottle reuse.