circular pro uk epr

New UK EPR obligations: What companies need to know from 2025 onwards    

On 1 January 2025, a modernised Extended Producer Responsibility (EPR) system for packaging came into force in the United Kingdom. The new regulations impose numerous obligations on companies that sell packaging or EPR-relevant products on the British market. The aim of the reform is to make manufacturers more accountable and improve recycling rates in the country. 

What’s new? 

The new law replaces the previous regulations. PackUK is responsible for monitoring compliance. Reporting requirements will apply to all packaging placed on the market in 2024, with retroactive effect from 2025. 

The EPR requirements apply to companies based in the United Kingdom that exceed certain turnover and volume thresholds. Large organisations in particular – companies with an annual turnover of more than £2 million and over 50 tonnes of packaging per year – must meet extensive requirements. 

EPR-Reporting Deadlines   

All relevant packaging data for 2024 and 2025 must be collected, documented and reported on time. The first deadline for data submission is already in April 2025. Companies should adapt their internal data management processes accordingly now. 

EPR fees: provisional values published 

Defra (Department for Environment, Food & Rural Affairs) has published initial fee rates based on the costs of local waste management, which will be billed in 2025. They apply to household packaging placed on the market in 2024: many, but also in many other countries, mostly in Europe.  

  • Plastic: £485 per tonne  
  • Aluminium: £435 
  • Paper/cardboard: £215 
  • Glass: £240   

From 2026, an additional ecological differentiation (modulated fees) is planned, which will be based on the recyclability of the packaging.  

RAM assessment requirement for large companies  

Since January 2025, large organisations have also been required to assess the recyclability of their household packaging using the Recyclability Assessment Methodology (RAM). The RAM categorisation is based on a traffic light system: 

  • Green: Easily recyclable 
  • Yellow: Limited recyclability 
  • Red: Not recyclable  

The results must be reported by 1 October 2025 at the latest. The RAM assessment is also likely to influence the level of fees in future, so companies should consider optimising their packaging designs at an early stage. 

Plastic packaging tax: increase & new calculation basis 

In addition to the EPR requirements, the Plastic Packaging Tax (PPT) was increased on 1 April 2025: packaging containing less than 30% recycled plastic is now subject to a tax of £223.69 per tonne. Another new feature is the planned mass balance approach, which allows chemically recycled plastic to be credited on a pro rata basis. 

Important: The previous advantages of ‘pre-consumer waste’ no longer apply. Reporting and certification processes must be adapted. 

What companies should do now 

To enable companies to respond to the new regulations in a legally compliant and economically efficient manner, we recommend the following measures: 

  • Collect packaging data: Record data for 2024 and 2025 in a structured manner and report it on time.  
  • Perform RAM categorisation (only for large organisations): Review packaging designs and adapt them if necessary. 
  • Revise cost planning: Factor in EPR and PPT levies.
  • Involve suppliers: Clarify recyclability and material composition at an early stage. 
  • Keep an eye on deadlines: The first deadlines are already in April and October 2025. 

Conclusion: Preparation creates competitive advantage

With the new UK EPR system, the United Kingdom is pursuing ambitious recycling targets and relying on clear financial incentives. For companies, this means more responsibility – but also the opportunity to save costs in the long term and gain competitive advantages through optimised packaging design. 

Would you like to know how your company is specifically affected?

Book your EPR support session with our team of experts now and find out whether your company is affected by the new EPR regulations.