Packaging EPR: June Announcements Update

On Friday 27 June, Defra and PackUK made a series of announcements related to Extended Producer Responsibility for Packaging (pEPR).

The letter from PackUK can be read here. The joint letter from Defra, DEARA, Scottish Govt. and Welsh Govt. can be read here.

Read on for a full summary of the key announcements.

Final Base Fees for Year 1 (2025/26) published

Material	NEW Rate (£ per tonne)	OLD Rate (£ per tonne)
Aluminium	266	435
Fibre-based composite	461	455
Glass	192	240
Paper or board	196	215
Plastic	423	485
Steel	259	305
Wood	280	320
Other	259	280

• All fees have gone down apart from fibre-based composites. Notably, glass has gone down by 20%.
• Bad debt contingency has gone down from 6% to 4%.
• More information on the fees, methodology and how this release differs from previous releases is available here.

UK to use existing powers to ensure EPR fees are spent on household packaging waste management and recycling (England ONLY)

• The Secretary of State for Environment, Food and Rural Affairs has instructed PackUK to exercise its existing powers within the pEPR regulations to ensure local authorities (in England) only receive pEPR funds that are spent on household packaging waste management and recycling.
• When local authority payment allocations are confirmed in the coming weeks, PackUK will write directly to local authority chief executives establishing clear accountability measures and expectations on how fees are spent.
• If an English local authority does not spend the funds as specified, PackUK will then use its existing regulatory powers to deduct funds accordingly from the following year’s payment.
• However, enforcement measures remain unclear and PackUK will need to further work through this aspect. UPDATE: Local authorities will have to report data to PackUK on the amount of money put to waste management services. 

No compliance action on H1 2025 Recyclability Assessment data

• After significant calls from BRC and members, the environmental regulators have issued a regulatory position statement concerning Recyclability Assessments for H1 2025 data, stating that there will be no compliance action if businesses choose not to:
  • Assess the recyclability of household packaging supplied in the reporting period 1 January to 30 June 2025.
  • Keep records of the recyclability assessments.
  • Report the recyclability assessments to the Environment Agency on or before 1 October 2025. 
• There will still be a requirement to record EPR tonnages data for different material types, including flexible and rigid plastics separately.
• The full PackUK statement is available here.

Modulation Policy confirmed

• PackUK released a three-year framework that will adjust producer fees based on packaging recyclability, as assessed through Recyclability Assessment Methodology (RAM) ratings.
• Starting from the 2026/27 financial year, the policy will apply escalating modulation factors from 1.2x, 1.6x and 2.0x over consecutive years for the Red category.
• H2 recyclability assessment data will be used to support this.
• The Red rate will subsidise the discount given to Green rated packaging.
• Therefore, as the modulation factor increases for Red, Green should have a larger discount year on year.
• The full PackUK statement is available here.

Next steps for Dual Use Packaging

• Defra held a ministerial roundtable and an industry workshop on issues related to dual use packaging  to gather feedback and find a path forward. Read our summary of the roundtable here.
• Industry have proposed several solutions and have set up further sector-sector specific workshops over the coming weeks to develop concrete proposals for how industry could reliably evidence claims that packaging does not enter a household waste stream but is instead handled commercially. Let Naomi know if you would like to attend these.
• Defra are due to consider the proposals with a view to identify which option(s) adequately address the issues whilst maintaining the objectives of the scheme.

Interim PackUK Strategy released

• The PackUK long-term strategy will be launched later in 2025.
• The interim strategy can be found here. This includes a line that states PackUK may bring Efficiency & Effectiveness 2028 assessments forward.

Next steps for Packaging (Export) Recovery Notes

• Defra are looking to improve compliance on material exports under ‘Green List’ waste processes.
• Defra have legislated for enhancements to the exporter accreditation process to strengthen the evidence requirements for issuing PERNs. These reforms come into effect on 1 January 2026.
• Consultation on levelling the playing field between domestic PRNs and export PERNs to launch later this year.

BRC next steps

• Continue to emphasise that pEPR remains a significant cost to industry, further exacerbating inflationary pressures.
• Advocate for clear enforcement measures to ensure Local Authority accountability on spending.
• Gather more details on how the government will drive efficiency and effectiveness in the system.