A full update will be provided from Defra via their newsletter but the main points from the Circular Economy Joint Stakeholder Forum on 3rd March is summarised below.
Deposit Return Scheme - Deposit Management Organisation (DMO)
- Sign up to the newsletter and find out about their webinars on Exchange for Change’s (the UK’s DMO) website.
- DRS@defra.gov.uk is Defra’s general inbox for queries on legislation.
Waste Crime
- A couple of weeks ago, two pieces of guidance were laid. Code of Practice on Litter and Refuse Guidance and Litter enforcement powers: when and how to use them.
Circular Economy in Local Places
- Invited place-based circular economy initiatives in England to join the Circular Economy Pathfinders project. Deadline 26 March 2026. Email CircularEconomy-PathfindersEvaluationProject@defra.gov.uk.
- Non mandatory, case-study based, guidance has been published for mayoral strategic authorities.
Simpler Recycling
- 31st March 2027 - Reminder that plastic films and flexible packaging collections from all households and workplaces will come into force.
- Some pEPR funding will go towards Simpler Recycling
pEPR
PackUK
General update
- Feb – they have agreed recalculation approach with four nations, paid Q3 Y1 LA payments
- March – published operational plan, 3rd March Direct Debit quarterly payment due, PRO to be announced. Q4 Y1 LA payments due.
- April – PRO to be appointed formally with phased introduction of responsibilities e.g. modulation, comms, RAM. Sovereign function will be retained by PackUK. 1 April data reporting deadline for obligated producers.
- June – Plan to issue Notices of Liability (NoLs) to producers for Year 2
Recalculations and Resubmissions – Year 1 shortfall position
- PackUK confirmed there was no change to disposal fees for Year 1. UK Government have agreed to close the funding gap caused by 1) the higher-than-expected volume of resubmissions – they expect for this to stabilise somewhat over the coming years, and 2) the resubmissions have resulted in a reduction in the underpinning total tonnage data.
- Those who resubmitted data will receive an updated reduced NoL by end of March. This is also due to a decrease in PackUK administrative costs. Those with reduction of less than £25 will not receive a new NoL.
- Grant letters to be sent to LAs before end of March. Payment from England will include a top up from wider Government.
- Longer term – PackUK expect resubmissions to begin to stabilise however they want to improve data stability. They are exploring earlier data resubmission deadlines and using year 1 data to improve calculations – more detail in their operational plan. They are also exploring relaxing the requirement to exactly balance the books, i.e. not hold a surplus or deficit, and allow them to build in a buffer.
Other
- Producers must agree a payment plan formally with PackUK if paying via direct debit. Making the payment is not sufficient.
- Improvement Action Plan Pilots have concluded. Outcomes to be shared soon.
EA
- 1 April – Small producers to register for 2026 compliance year and report 2025 packaging data. Large producers to report H2 (June- December) 2025 packaging data, including RAM data, via the RPD service. There are updated data specification templates with refined clarifications.
- Online marketplaces – if you are reporting under the online marketplace function, you must submit your methodology annually to show how you determine the weights of the packaging you’re reporting to the EA by emailing packagingproducers@environment-agency.gov.uk. If nothing has changed, you must notify them that nothing has changed via email.
- Version 8 of the Regulators Agreed Positions and technical Interpretations is now published. Appendix 11 says what changes have been made.
- EA outlined their recent Regulatory Position Statements:
- RPS 351 Fibre based composites definition – provided producers the ability to report H1 2025 against the revised definition in the amending SI. This came into force 1st Jan therefore all producers must report in line with the updated definition.
- RPS 330 Nation of Sale, self-managed organisation waste and bags – this applies to 2024 and 2025 data collection and reporting only. From 2026, obligated producers must collect and report this data due 1 April 2027. Guidance on how to report is to be published soon.
- RPS 350 H1 2025 Recyclability Assessment Methodology obligations. From July 2025, obligated producers must undertake assessment on relevant packaging and report this data in their H2 2025 data onwards.
BRC Commentary
- We are pleased that the Government has listened to our calls to cover the shortfall on pEPR and will continue to work with Defra to make the necessary legislative changes to give businesses greater certainty and prevent this from happening again.
- BRC will continue to work on the set up of the Deposit Return Scheme alongside members – if you are not looped in to our mailing list for updates but wish to be, please let Naomi know.
- There was no further update on the Circular Economy Growth Plan but we continue to press for timelines to allow businesses to prepare accordingly.
Future Forum links:
- April Engagement Forum – Tuesday 14 April: 14:30: – 16:00 Link to access forum (This may change as Defra have moved the date)
- May Engagement Forum – Tuesday 5 May: 14:30 – 16:00: Link to access forum
- June Engagement Forum – Tuesday 2 June: 14:30 – 16:00: Link to access forum
- July Engagement Forum – Tuesday 7 July: 14:30 – 16:00: Link to access forum
