Government Tables Amendments to pEPR Scheme
Overview of the Amendments
The UK Government has submitted draft amendments to the packaging Extended Producer Responsibility (pEPR) regulations for Parliamentary approval. These proposed changes introduce a range of technical and operational refinements to the scheme, which has been in effect since January 2025.
The revisions are expected to take effect from January 2026 and are intended to resolve several issues highlighted during the scheme’s first year, including the interpretation of packaging material categories, obligations during corporate restructuring, and the overall administration of producer responsibilities.
Updated Definition for Packaging Materials
One of the main technical adjustments relates to the classification of fibre-based composite materials. The revised wording brings the definition in line with the Recycled Material Approval Mechanism (RAM).
Under the updated definition, fibre-based composite packaging refers to materials made primarily from paperboard or paper fibres, combined with one or more plastic layers that cannot be separated manually.
A key clarification has also been introduced:
- If the plastic layer represents less than 5% of the packaging’s total weight, the item must now be reported under the paper/board category, rather than recorded as a composite material.
Additionally, PackUK will be able to expand the criteria used for modulated fees. This allows the fee structure to better reflect whether packaging is proportionate and necessary, discouraging excessive or avoidable use of material.
Recognition of Closed Loop Collection and Recycling
For the first time, producers operating closed loop recycling systems will have the ability to offset some of their packaging waste against their EPR obligations.
To qualify, producers must:
- Collect food-grade plastic household packaging directly from the waste stream
- Ensure this material is recycled without being mixed with packaging from other producers
- Provide clear evidence that the waste has been reprocessed into new food-grade plastic
This adjustment is intended to encourage more circular manufacturing practices, particularly in sectors dealing with hard-to-recycle packaging.
Clarification on Mergers and Corporate Restructuring
The amendments also provide clearer guidance for organisations undergoing mergers or structural changes.
Following implementation, the merged organisation will be treated as a large producer if either of the former entities met the criteria for being classified as a large producer prior to the merger.
This is intended to prevent gaps or delays in reporting obligations during corporate transitions.
Role of Producer Responsibility Organisations
The amendments grant PackUK the authority to appoint one or more Producer Responsibility Organisations (PROs).
These industry-led bodies may be authorised to:
- Carry out specific operational tasks on behalf of PackUK
- Provide policy guidance
- Offer recommendations to support the ongoing development and stability of the pEPR framework
This move is expected to support a more structured and collaborative approach to implementing the scheme at scale.
The amendments reflect ongoing work to strengthen the pEPR framework and improve clarity around obligations for packaging waste across the UK. With clearer definitions, recognition of closed loop recycling, and expanded operational support, the scheme is moving towards a more consistent and accountable system for producers.
At Affordable Waste Management, we provide compliant commercial waste collection services across the UK, ensuring that businesses have reliable, lawful and straightforward arrangements in place for managing their waste.