Regulators Publish Updated Agreed Positions and Technical Interpretations (Version 7)

The UK environmental regulators have released Version 7 of the Regulators’ Agreed Positions and Technical Interpretations for Extended Producer Responsibility (EPR) for packaging.

The updated guidance, published jointly by the Environment Agency, Natural Resources Wales, SEPA and NIEA on 6 October 2025, provides further clarity on several key definitions and reporting requirements ahead of the 2026 obligation year.

• Explanations added for packaging type – there is now further guidance on packaging type (class), including the explicit definitions of primary, secondary, tertiary and shipment packaging in the text of the document.

• Revised definition of manufacturer – the guidance now redefines when a packaging component is considered “manufactured”, focusing on the last substantial modification. Producers must apply this interpretation for H2 2025 data onwards.
• Expanded guidance on reusable packaging – clearer definitions of “reusable” versus “reused” packaging, with new examples covering service providers, hired systems, and internal reuse.
• New section on packaging repairs – sets out when refurbishment or rebuilding of items such as pallets constitutes the manufacture of new packaging.
• Updated interpretation of group and subsidiary obligations – additional clarity for corporate groups, including overseas entities, on how turnover and tonnage thresholds are combined and how “mid-year changes” should be reported in RPD.
• New advice for distributors – an entirely new Appendix 10 outlines the evidence required to determine when unfilled packaging must be reported, and what information distributors must keep and submit.
• Clarifications on multi-branded and dual-branded packaging – further examples show which brand owner is obligated when multiple brands appear on the same pack.
• Additional examples for household vs non-household packaging – particularly relating to hospitality, installation services, and sale-or-return scenarios.
• Introduction of packaging material sub-categories – confirmation that from 2025 onwards, liable producers must separate flexible and rigid plastics within reported data, with future sub-categories to follow.
• Enhanced guidance on self-managed packaging waste – now split into self-managed organisation and self-managed consumer waste, with updated reporting flowcharts within the added self-managed consumer waste sub-section.
• Minor clarifications to appendices on labels, materials, commonly binned packaging, and the use of leaver codes for group reporting.

These updates continue to refine the interpretation of EPR regulations as producers prepare for the first disposal fee payments and the rollout of recyclability-based fee modulation from 2026.

Businesses should ensure their internal definitions, data capture methods and supplier communications are updated to reflect the new guidance, especially around manufacture, reuse systems, and distributor evidence requirements.

Keeping up with these constant regulatory developments can be complex and time-consuming. By leveraging Clarity’s data management expertise, producers can stay ahead without needing to interpret every legislative change themselves. Our dedicated compliance team monitors each new update to ensure your packaging data is always accurate, complete and aligned with regulator expectations.

We also work collaboratively with you to improve data quality, reduce future EPR costs, and strengthen compliance confidence. Supported by intuitive tools, including RAM Assess,  we make it easier to stay compliant today while preparing for a more efficient, cost-effective EPR future.

The full Extended Producer Responsibility for Packaging: Regulators’ Agreed Positions and Technical Interpretations – Version 7.0 (October 2025) can be downloaded from GOV.UK here.

For further support in understanding how these changes affect your business, simply reach out to our team by completing the details below and we’ll be in touch.