Update: Amends to the packaging EPR recycling labelling deadline

A future requirement of packaging Extended Producer Responsibility (pEPR) is that organisations must display a recycling label on primary and shipment packaging, with instructions on how to recycle it correctly. This is to inform consumers and help them make the correct choice when disposing of used packaging.

The Department for Environment, Food, and Rural Affairs (Defra) overseeing the transition to pEPR confirmed in their recent Business Readiness Forum on 11th April 2024 that the deadline for organisations to label their packaging has been pushed back to 1st April 2027 for all primary and shipment packaging:

Defra define these types of packaging as:

Primary packaging: is packaging conceived to constitute a sales unit to the final user or consumer at the point of purchase. 
Shipment packaging: is packaging added in addition to primary packaging, on items which are sold online or by mail order which are either delivered direct to the purchaser or collected by the purchaser from a shop or other collection point after they have been purchased.

Secondary and tertiary/transit packaging which are used within the supply chain, do not need to be labelled with recycling information.

Previously, primary and shipment packaging except film and flexibles must be labelled by 31st March 2026, followed by the remaining film and flexible packaging needed to be labelled by 31st March 2027. The later date for plastic film and flexible packaging was to reflect the expected increased capacity for recycling of these formats from kerbside collections by March 2027, via the English Government’s Simpler Recycling policy.

The deadlines to label plastic film and flexible packaging and all other packaging materials are now corresponding and has shifted by one day to by the 1st April 2027.

The ‘Main pEPR Regulations’ which bring this labelling requirement into law, are not yet in force. Defra has acquired a licence agreement with WRAP, to use the Recycle Now logo in Defra-designed labels. This licence agreement will come into force when ‘The Main pEPR Regulations’ come into force, which is expected in late-2024. Once in force, the provisions of these Regulations are UK law, which means that the labels become available to use, free of charge, for organisations.

Defra will only have 2 labelling options, which will simply state:

  • ‘Recycle’
  • ‘Do not recycle’

Producers can prepare in advance by becoming a member of On Pack Recycling Label (OPRL). OPRL is a UK-wide recognised labelling scheme which utilises the Recycle Now logo, from an existing licence agreement with WRAP. An organisation can join this paid scheme as a member, in advance of the ‘Main pEPR Regulations’ coming into force and the Defra labels becoming available.

For further information and to catch the latest updates on packaging EPR & labelling requirements, subscribe to Defra’s Resources & Waste Newsletter here.

Beyondly Members

Access our recent webinar (April 2024) with OPRL; Extended Producer Responsibility (EPR); preparing for the future of labelling with OPRL, on your member portal, within the message section.

Click here!


Packaging with recycle symbol in it