2025 marked a pivotal year for UK packaging regulation, as producers began to feel the practical and financial impact of the UK’s packaging Extended Producer Responsibility (pEPR) reforms.
The publication of Year 1 EPR base fees, alongside the first pEPR invoices and the confirmation of recyclability-based fee modulation through the Recyclability Assessment Methodology (RAM), signalled a clear shift from policy design to active implementation.
This article provides an overview of the key regulatory developments that shaped 2025 and highlights the areas producers should be preparing for as the regime continues to develop through 2026 and beyond.
Base Fee Confirmed
PackUK published updated EPR base fees for packaging data placed on the market in 2024. This provided long-awaited clarity for obligated businesses ahead of invoicing, which began in October 2025.
The confirmed base fees were lower than earlier estimates for most material types, offering some short-term relief for producers. However, fibre-based composite materials saw a modest increase, reflecting the higher net cost of managing these materials within the current system.
Fees for glass packaging reduced materially compared with previous projections. Despite this, concerns remain within the glass sector due to the continued use of weight-based cost allocation, which may have longer-term implications as the scheme matures and local authority cost data stabilises.
New Packaging EPR updates Laid in Parliament
Amendments to the Packaging Waste Regulations were laid before Parliament in early November 2025 and introduce several important changes to the operation of pEPR that will affect producers.
Key updates include:
- Appointment of a Producer Responsibility Organisation (PRO)
The regulations enable the appointment of a Producer Responsibility Organisation (PRO), an industry-led body intended to support operational decision-making and help shape the future direction of the pEPR scheme. PackUK intends to appoint the PRO in March 2026.
- Updated definition of fibre-based composite material
The definition of fibre-based composite packaging has been revised to better align with the Recyclability Assessment Methodology (RAM). As part of this change, fibre-based composite packaging containing less than 5% plastic by weight will instead be reported under the paper and board material category.
- Further provisions affecting fee calculation and application
The amended guidelines enable PackUK to extend the criteria used for pEPR fee modulation and to vary charges where packaging is not considered reasonably necessary or proportionate to its intended use.
- Closed-loop recycling offset mechanism
Producers can offset pEPR fees for packaging collected and recycled through closed-loop systems, reported under the self-managed consumer waste category.
Further detail on the amended regulations is available on the GOV.UK website.
Fee Modulation Framework Confirmed
PackUK also published the fee modulation framework, confirming that modulated fees from 2026 onwards will increase based on recyclability performance.
Modulated fees will be calculated using the RAM Red, Amber and Green ratings, with harder to recycle (Red-rated) packaging attracting higher costs. The confirmed escalation factors are:
- 2026: 1.2 × base fee
- 2027: 1.6 × base fee
- 2028: 2.0 × base fee
These increasing modulation factors underline the importance of accurate data collection and proactive assessment of packaging design. Producers that invest in robust data, assessment tools and packaging design improvements will be better positioned to manage future compliance costs.
RAM Assess is designed to support exactly this challenge. It helps producers complete RAM assessments accurately and at scale by automating component classification and highlighting missing or incomplete data early. With built-in reporting outputs and cost insight, RAM Assess also enables teams to model the financial impact of recyclability changes and prioritise the packaging improvements that will deliver the greatest compliance and cost benefits as modulation increases from 2026 onwards.
Prepare for 2026
Building on the developments seen in 2025, the early years of PackUK’s pEPR scheme continue to be characterised by regulatory change as the foundations of this UK-wide framework are established. Further guidance updates and refinements to reporting requirements should be expected as the regime matures.
From 1 January 2026, additional data collection requirements apply under the regulators’ Regulatory Position Statement (RPS), including:
- Nation of sale data – collection begins from 1 January 2026, with reporting due on or before 1 April 2027.
- Self-managed organisational waste data – collection begins from 1 January 2026, with reporting due on or before 1 October 2026.
RAM reporting also becomes a mandatory component of submissions for H2 2025, with assessments due in February 2026. Where RAM data for H1 2025 has not been submitted, PackUK may extrapolate recyclability outcomes from H2 data for charging purposes.
From the 2026 to 2027 scheme year, producers will also begin to see the financial impact of recyclability-based fee modulation reflected in EPR charges, further increasing the importance of data accuracy and informed packaging decisions.
How Clarity Can Help
As pEPR continues to evolve, early preparation will be essential to reducing compliance risk and controlling future costs. Producers should review their data collection processes, assess the recyclability of their packaging portfolio, and understand how modulated fees could impact their business from 2026 onwards.
For Clarity scheme members, RAM Assess is the recommended way to complete your RAM assessment accurately and at scale. It streamlines classification and RAG rating, highlights missing or incomplete data early, and helps you produce consistent, audit-ready outputs for submission.
