pEPR amendments sent to the EU and other updates
|
Member actions |
High-level overview; no immediate action required. |
|
Key takeaways |
|
Amendments to pEPR Regulations
On 6th May 2025, the UK Government sent notification of amendments to the pEPR Regulations to the EU. Once reviewed by the EU, these amendments will be laid before Parliament in November 2025 to come into force in January 2026.
Defra have said that as part of their commitment to respond to feedback from across the value chain, they have engaged with and listened to stakeholders, whose feedback has been instrumental in shaping the development of pEPR to help deliver a more effective and efficient scheme.
Some of the key changes are:
The appointment of a Producer Responsibility Organisation (PRO)
Much like other schemes in Europe, this change in regulations will allow the transfer of functions from the Scheme Administrator (PackUK) to the PRO to enable greater producer leadership in the operation of pEPR. An expression of interest process has been launched for interested candidates which you can find here. This should automatically land in your Downloads folder.
Offsetting for closed loop recycling systems for food grade plastic
To incentivise producers to establish and develop closed loop systems that preserve the quality of recyclate and produce high-quality food grade plastic, obligated producers will be able to offset household disposal fees where they collect and recycle food grade plastics. This will help with innovation in the industry and reduce reliance on virgin plastic.
The dual-use packaging question
While not included in these amendments, the Government recognises the issue of packaging which can be discarded by both consumers and businesses currently captured by the household packaging definition. Earlier this year, Defra undertook sprint sessions with industry to explore scenarios and outcomes, in line with considered international examples to help tackle this issue and lead to a fairer outcome for producers. Unfortunately, no consensus was agreed upon in these sessions, with industry raising concerns that established international models will not work effectively for many UK business models, and where countries have allowed producers to self-report on their household vs non-household packaging, this could create increased complexity, enforcement costs, and therefore higher fees.
Again, the Government recognises the importance of this issue and will be working with previously contacted stakeholders later in the year to begin a series of co-design activities to explore proposals and to find a workable solution, subject to ministerial agreement.
RAM v1.1
Following stakeholder engagement and feedback, last week PackUK published their updated and simplified version of the RAM for the 2025 compliance year. Key takeaways include; the removal of certain data points leading to reduce complexity in the assessment requirements and clarified guidance for increased ease of understanding.
Beyondly packaging compliance scheme members can find our updated guidance in the resources section of our online portal which includes links to the full government guidance.
It was also announced that there will be a new Agreed Positions document released imminently to compliment the guidance already released.
Reporting requirements under RAM
Continuing the theme of listening to feedback from producers, the regulators acknowledge concerns around the time and resource requirements to complete recyclability assessments in the time left before reporting the first bi-annual submissions in October for 2025 data and are continuing to engage with compliance schemes and producers. Beyondly is actively involved in engagement activities and remains well-positioned to support members.
Outside of pEPR
To continue the bumper update from the Government:
Announced changes to Plastics Packaging Tax (PPT) brought forward
The changes to PPT to allow a mass balance approach for chemically recycled plastic has been brought forward by two years to come into force from April 2027. For an in-depth dive into the changes, please see our latest news story.
Strengthening the Packaging Recovery Note (PRN) system
During the remainder of 2025, Defra will be working with the value chain on reforms to the PRN system. The aims of these reforms will be to help level the playing field between domestic re-processors and exporters, as well as looking at measure to reduce price volatility and therefore stabilise the PRN market, and to reduce the exporting of plastic waste.
Deposit Return Scheme (DRS) for drinks containers
On 6th May 2025, the operators of the DRS for single-use plastic and metal drinks containers in England, Northern Ireland, and Scotland has been announced as UK Deposit Management Organisation Limited (UK DMO). The appointment has been made in England and Northern Ireland, with slight amendments to the Scottish DRS Regulations needing to pass through Scottish Parliament before being designated as the Schemed Administrator in Scotland.
The next step for UK DMO will be to begin engagement with partners and businesses to design, set up, and operate the scheme. DRS is due to launch in October 2027 in the three nations with the aim of reducing litter, following the principle of litter attracts litter, and to increase the quality of recyclable materials by having designated drinks container collection points.
The Defra policy statement published 7th May 2025 is available here.
Government committed to supporting glass reuse
Reuse is a key part of the UK’s transition to a circular economy. In the current pEPR Regulations, producers are only required to report and pay for packaging the first time it is placed on the market, as well as being able to offset against their costs reusable packaging they are collecting from consumers to send to be recycled. This creates opportunity and incentives for businesses to think about how they can incorporate reusable and reused packaging into the supply chain.
Defra is looking to increase support, with focus on the UK glass industry, for the development of reuse and refill for on-trade glass bottles in closed environment settings or public sector establishments, such as festivals or hospitals. Government recognises the potential that glass reuse must support emission reductions in an industry already working hard to make progress and meet targets, and Defra intends to continue discussions with the sector to help support a transition to glass reuse.
In autumn, we will see a call for evidence with a focus on measure to support and incentivise reuse.
To add a note of clarification on these final two points regarding Wales, the Welsh Government are committed to developing a DRS and develop glass reuse in the context of their already high levels of recycling.