Recyclability is a dynamic concept, which can be hard to define. Defra are currently working to produce an industry accepted definition, which will focus on three key considerations for UK packaging recyclability:
- If the packaging material is ‘technically’ capable of being recycled?
- If the collection and sorting infrastructure is in place to enable the packaging to be recycled
- That the material once recovered and recycled can be used to produce new products
The increase or decrease of fees to incentivise producers to make more sustainable decisions when designing or purchasing packaging. The phrase ‘adjusted’ is often used by Defra.
Defra have confirmed that modulated disposal fees from 2026 have initially been designed as a two-tier system, with one higher rate for materials that Defra want to disincentivise, and a second lower rate for all other packaging.
Disposal fees will be invoiced to large organisations based on the tonnage of household packaging they place on the UK market and its recyclability. These fees will shift the cost of collecting and managing household packaging waste from local authorities to packaging producers.
Disposal Fees will be introduced in 2025 in a phased approach. Fees in 2025 will be invoiced per broad material category, then from 2026, fees be modulated based on the specific packaging format and its recyclability.
Defra are developing a Recyclability Assessment Methodology (RAM) which will assess packaging against the recyclability criteria for the purpose of whether to label packaging with ‘Recycle’ or ‘Do Not Recycle’ and beyond early years of modulated fees, determine disposal fee rates. Producers will be required to keep the results of the RAM for 7 years. The RAM will be determined by the pEPR scheme administrator and can be completed by the producer or a third party.
The pEPR draft regulations propose Recycling Information Regulation. This requires producers to label all primary and shipment packaging with ‘Recycle’ or ‘Do Not Recycle’ with the aim of instructing consumers how to dispose of their used packaging.
