Corporate report

PackUK: operational plan 2024 to 2025

Published 28 February 2025

Introduction

2025 to 2026 will be the first full operational year that PackUK will be in existence. PackUK has an obligation under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 to publish an operational plan for the upcoming scheme year.

The joint policy statement on extended producer responsibility for packaging provides additional details on what the four nations expect to be covered in this operational plan. For the upcoming scheme year, there are a number of topics that are out of scope of the operational plan which are:

• the total amount of chargeable disposal costs of all relevant authorities

• the total costs PackUK expects to incur to cover public information campaigns and administration

• the total amount PackUK expects to recover from obligated producers

Final fees for the first year of EPR will be released after 1 April 2025 (the deadline for reporting packaging supplied by registered producers in 2024) which means that PackUK is unable to provide accurate forecasts for the costs PackUK expects to incur to cover public information campaigns and administration and the amounts PackUK expects to recover from obligated producers. The areas which are in scope of the operational plan are:

• modulation and key finance dates

• financial services supplier

• efficiency and effectiveness

• statutory obligations

Fees and payments

Forecasts

In December 2024, PackUK published the latest iteration of illustrative base fees and indicative amounts that will be paid to local authorities. As these amounts are subject to change, as we receive more data and calculate for accurate amounts, we are unable to provide forecasts for the amount PackUK expects to recover from obligated producers and the amount of chargeable disposal costs given to local authorities.

PackUK expects to incur public information disposal costs which will cover the costs of any public information campaigns PackUK wishes to launch that will aid in the environmental outcomes it hopes to achieve. To oversee the implementation and running of the pEPR reforms, PackUK will incur administration costs that will cover all aspects of running the scheme.

Key Dates

October 2025 – Invoices will be sent to obligated producers, which will include disposal fees, administration and public information campaign costs. Producers will have 50 days after the date of the invoice to make payment in full or set up quarterly instalments.

We expect quarterly payments to be made in:

• November 2025

• January 2026

• April 2026

• June 2026

November 2025 - It is expected that local authorities will receive their first payment in November 2025 for Q1 and Q2 of the assessment year April 2025 to March 2026. Future payments will be made to local authorities in:

• January 2026

• March 2026

December 2025 – PackUK will confirm the arrangements for modulated fees which will be due to begin in 2026.

Modulation

From the second operational year of EPR (2026 to 2027), fees will be modulated to ensure packaging materials that are less environmentally sustainable incur higher fees. The types of packaging which will be subject to higher or lower modulated fees will initially be based on recyclability assessments in line with a recyclability assessment methodology (RAM) which was published in December 2024.

The outline modulation methodology is due to be released in spring 2025.

Public information campaigns

PackUK has a statutory obligation to make available information on the reuse of packaging; the recovery, including recycling, and disposal of packaging waste; and the prevention of packaging litter.

In order to meet this statutory obligation, PackUK can make arrangements for national or local information campaigns that will inform the public and businesses about how to manage, reuse and recycle their packaging waste as well as preventing packaging litter.

PackUK will be developing its public information campaigns throughout the first operational year. These campaigns should support delivery of environmental effects that the scheme is seeking to achieve. These environmental effects are:

• the use of environmentally sustainable packaging

• the prevention of packaging becoming waste

• an increase in the reuse of packaging, and in the quantity and quality of packaging materials recycled; and a reduction in the packaging material placed on the market.

Financial services supplier

For the upcoming operational year, PackUK will focus on the implementation and mobilisation of the financial services supplier (FSS) ahead of invoicing in October 2025. The FSS will oversee the collection of fees from obligated producers and the issuing of payments to local authorities.

Producer responsibility organisation

For the upcoming operational year, PackUK will lay the groundwork to establish the producer responsibility organisation (PRO), developing the role of the PRO and the application process with an aim of appointing in order to delegate Scheme Administrator functions to. This work will identify the initial role of the PRO in delivering scheme functions and a robust application process to ensure a high-quality candidate with the support of producers is appointed.

Efficiency and effectiveness

PackUK will carry out assessments on local authorities to assess the efficiency and effectiveness of the collection and recycling services for packaging waste. In doing so, it will deliver a scheme which demonstrates value for money for both producers and citizens.

In April 2025, PackUK is due to send further indicative payment letters and associated guidance, including guidance on effectiveness to local authorities, ahead of final payment letters being send in November 2025.

From May 2025, work will run in parallel on the procurement of the agent working on behalf of PackUK and the commencement of a framework for the support organisations. PackUK will also be developing a suite of support and eligibility criteria for local authorities in an improvement action plan. There are also plans to conduct a pilot study with a handful of local authorities across all four nations for the improvement action plan work.

PackUK will develop and maintain a resource library for local authorities to use and provide feedback on by November 2025.

This will happen in parallel with ongoing engagement with local authority representatives, understanding the interactions between policies and the four nations and looking to develop a greater understanding of the data issues faced by local authorities. We will use pilots to ensure that improvement actions integrate with existing improvement frameworks of each nation.

Statutory obligations

PackUK has a number of statutory obligations under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. To satisfy these obligations in the upcoming operational year, PackUK will carry out the following activities.

• statement of policy for the modulation of disposal fees – PackUK will aim to publish this in June 2025 in order to provide as much time as possible to obligated producers

• strategy – PackUK will publish a strategy in June 2025 which will include the objectives and functions, governance arrangements of the scheme and the outcomes it intends to achieve

• annual report and statement of accounts – PackUK will publish an annual report and statement of accounts in September 2025, in line with Public Sector Fraud Authority (PSFA) and International Financial Reporting Standards (IFRS) accounting standards

• notices of assessment and liability – October/November 2025, PackUK will send all requires notices to be send to producers and local authorities

• producer and local authority guidance – PackUK will look to publish guidance to both obligated producers and local authorities on areas such as fee calculation, payment methodology and efficiency and effectiveness. This guidance will be published in parallel when further information is available on the previously mentioned topics.

• lists – PackUK must publish a list of items of packaging which are commonly disposed of in public bins or as ground litter, from the best evidence available to the PackUK. These lists will be published as soon as PackUK gathers the necessary evidence to publish