Policy paper

UK joint policy statement on packaging Extended Producer Responsibility

Published 27 February 2025

Purpose of the document

This policy statement is being made jointly by the Secretary of State for DEFRA, and Ministers in DAERA in Northern Ireland, Scottish Government and Welsh Government (‘the Four Nations’). It is required by the Packaging Regulations 2024^{[footnote 1]} and sets out the intended environmental effects of the Extended Producer Responsibility (EPR) for packaging policy and how it is intended that the policy will achieve those effects. Specifically, it covers the core governance documents the Scheme Administrator must publish in 2025; outcomes we expect the Scheme Administrator to work towards; and the deliverables the Four Nations expect in its first year of operation.

Scheme Administrator Governance Documents

In the first year of EPR for packaging, the Scheme Administrator must publish the following documents that articulate, at a high level, its approach to meeting the outcomes and deliverables set out in this document.

• A strategy (the “Strategy”) by no later than June 2025 meeting the requirements detailed in Schedule 7 to the Regulations.  This includes the Scheme Administrator’s objectives and functions, outcomes it seeks to achieve, governance arrangements, delivery arrangements, how these support the outcomes of the scheme; how the Scheme Administrator intends to engage with those with a legitimate interest in the way it performs its functions; and how it intends to measure and report on delivery of its objectives and scheme outcomes.
• An operational plan (the “Operational Plan”) each year no later than 28 February meeting the requirements detailed in Schedule 7 to the Regulations.  This includes priorities for the coming financial year starting on 1 April (the operational year), forecasts of disposal costs of local authorities and for public information campaigns, its approach to calculating disposal fees payable by liable producers, and public information and other communication activities it proposes to conduct in the operational year.

The Four Nations will work with the Scheme Administrator over this initial set up and delivery phase, including in relation to the Scheme Administrator’s first strategy.  Governments will also update the policy statement as necessary, for example, to take account of future developments relating to circular economy policy for packaging and the Scheme Administrator’s role in its delivery.

Summary of intended outcomes

In the delivery of its functions under the Packaging Regulations 2024, the Scheme Administrator must act in accordance with the need to facilitate the achievement of the environmental effects set out in this policy statement. ^{[footnote 2]} 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.

The Four Nations consider the delivery of these outcomes, including through the Scheme Administrator, as central to supporting the transition to a circular economy, whilst maximising the carbon efficiencies associated with the lifecycle of packaging materials.

 Key policy measures – Year 1 deliverables

Producer base fees and modulation

The EPR for packaging policy introduces an obligation for producers to pay for the collection and disposal costs of their household packaging when it becomes waste. This aligns producer responsibility for packaging with the polluter pays principle. In setting producer fees, the Scheme Administrator should deliver against the relevant objectives and desired outcomes of the policy.

The Scheme Administrator should publish final base fees for the 2025/26 year no later than June 2025, on the basis of timely submissions of sufficient producer data reported into the EPR for packaging digital service (Report Packaging Data), enabling satisfactory regulatory checks. The introduction of base fees will incentivise producers to improve design and place less material on the market, resulting in the prevention of packaging becoming waste.  The Scheme Administrator must use fee modulation from 2026/27 onwards to incentivise the move to recyclable and reusable packaging. 

The Regulations require the Scheme Administrator to publish a statement of policy on modulation as soon as is practical after its establishment and then review that policy at least every three years thereafter.  The Four Nations expect this first policy statement to be published alongside the Scheme Administrator’s Strategy, no later than June 2025.  The first statement of policy on modulation should seek to:

• drive producers to use household packaging that is easier to recycle or reuse,
• apportion fees to material groups in a way which supports the delivery of the intended outcomes of the scheme, factoring in disposal costs and improved environmental outcomes, including where feasible carbon impact,
• articulate how modulation in particular will encourage the use of easier to recycle packaging and a move to reuseable alternatives, and
• in addition, articulate how fees will support recycling at scale.

The Four Nations also expect the Scheme Administrator to address sustainability more broadly in the development of its Strategy. The Scheme Administrator will be expected to consider how it can support the reduction of the environmental impacts of the manufacture, transportation and use of the packaging, as well as the environmental impact of packaging when it becomes waste. It will also be expected to contribute fully to the delivery of international and domestic obligations to decarbonise.^{[footnote 3]} ### Recyclability assessment methodology  

To support producers in making this packaging material transition, the Scheme Administrator must develop and maintain a recyclability assessment methodology and should publish this as soon as possible after establishment^{[footnote 4]}. The methodology will provide a standardised method for producers to assess the recyclability of packaging and will inform the modulation of producer fees. The methodology should be updated on an annual basis in line with EPR for packaging reporting cycles.

Local authority efficient and effective management of packaging waste

The Scheme Administrator must calculate and distribute payments to local authorities for the efficient collection and disposal of household packaging waste. Payments should enable local authority services to deliver against the objectives set out in this statement whilst accounting for the relevant domestic policies in each nation^{[footnote 5]}.  

In making an assessment of efficient disposal costs, the Scheme Administrator will consider the disposal costs which a local authority would incur if it were providing an efficient waste management service, which is a service where costs are as low as reasonably possible, taking into account any other factors specific to that authority, while supporting the requisite scheme outcomes.

The Scheme Administrator must produce guidance on the methodology and procedure that it will use and, where relevant, the factors it will consider in assessing efficiency as soon as practical after its establishment.  The Four Nations expect this guidance to form part of the Operational Plan. An estimate of payments that will be made to local authorities must be provided to local authorities as soon as reasonably practicable for the 2025 assessment year. For subsequent years, the Scheme Administrator must provide an estimate of payments no later than 1 November 2025 ahead of that assessment year^{[footnote 6]}.

Under the Packaging Regulations 2024, from 2028 the Scheme Administrator must assess the extent to which each relevant authority is providing an effective waste management service in relation to household packaging waste. However, the Four Nations expect the Scheme Administrator to initiate these assessments earlier than this where it is satisfied it has sufficient data to make those assessments.  This is to ensure that local authorities are given early support and assistance to improve performance where this is possible.

The proposed initial metrics for assessment of efficiency and effectiveness of local authority disposal costs were included in notification of indicative payments to local authorities on 28 November 2024.  The Scheme Administrator should review at least annually the approach and methodology for assessing an efficient and effective service, in order to deliver the scheme’s environmental outcomes, and ultimately keep high-quality materials in use for longer. In its strategy, the Scheme Administrator should set out how it intends to develop this assessment as cost and performance data improves over time.

Public information campaigns

The Scheme Administrator must deliver public information campaigns to provide consumers and businesses with information about how to recycle, re-use and dispose of packaging, and prevent packaging from becoming litter. In developing public information campaigns, the scheme administrator should consider how they will complement campaigns delivered at a local and nation level alongside the available information across the waste management ecosystem to  enable consumers and businesses to play their part, increase the quality of material for recycling and re-use, and reduce littering and the unnecessary residual disposal of packaging.

The Scheme Administrator should set out its plans for public information campaigns in its Strategy and the specific campaigns and communication activities it proposes to conduct for the coming year in its Operational Plan, including how these will be targeted to improve recycling and reuse performance for specific packaging materials and how these will be tailored to address the context in each nation. The Strategy should also outline how formal governance structures will oversee public information campaigns and communication activities.

Measuring and reporting on progress

In its Strategy, the Scheme Administrator is required to set out how it will measure and report on delivery of its objectives and outcomes. The key performance indicators it will apply will be set out in its yearly Operational Plan.

In addition, the Four Nations expect the Scheme Administrator to use the Strategy and Operational Plan to set stretching objectives, goals and performance standards that take account of expectations set out in this policy statement and deliver against both scheme outcomes and a quality service for businesses and local authorities who interact with the Scheme Administrator.

The Four Nations will monitor the Scheme Administrator’s performance, including through the Scheme Administrator’s annual report, the first of which will be due by 30 September 2026 for year 1 of EPR for packaging and each year thereafter.

Should the Scheme Administrator fail to set suitably stretching objectives, goals or performance indicators, or deliver against them, the Four Nations will consider whether it is appropriate to rely on their powers contained in regulation 59 of the Packaging Regulations 2024 to formally direct the Scheme Administrator to take, or refrain from taking, specified actions in order to improve performance.

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1. The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. ↩

2. The Packaging Regulations 2024, regulation 127 ↩

3. The Packaging Regulations 2024, regulation 64(7) ↩

4. The Packaging Regulations 2024, Schedule 7(7) ↩

5. The Packaging Regulations 2024, regulation 73, paragraph 1(c)(v) ↩

6. The Packaging Regulations 2024, regulation 74 ↩