2025 introduces pivotal changes in packaging reporting under Extended Producer Responsibility (EPR), with increased reporting obligations including the implementation of the Recyclability Assessment Methodology (RAM) and the first Scheme Administrator payment. Proactive planning and thorough data collection are essential to ensure compliance, prevent overpayment, and facilitate seamless submissions.
The following dates outline key milestones for 2025, offering a clear guide on what to expect and when to prepare. While this reflects the most up-to-date information available, we are committed to keeping you informed of any significant updates as they arise.
Overview of Key Deadlines
Q1 2025 - January, February, March
January:
- 2025 introduces a new Environment Agency registration fee (£2,620) for large producers who are direct registrants (i.e. not part of a compliance scheme), with additional subsidiary costs if applicable to your business.
- Start collecting 2025 packaging data using the Recyclability Assessment Methodology (RAM). Household packaging placed on the market from January 2025 will need to be assessed using the RAM. For more information on the RAM, click here to read our article Final Recyclability Assessment Methodology (RAM) Published.
March:
- Complete collation of your H2 2024 (July–December) data ahead of 1st April deadline.
Q2 2025 - April, May, June
April:
- Submit your H2 2024 (July–December) data submission by 1st April.
Ongoing this quarter:
- Continue collecting and tracking packaging data for H1 2025 (January–June), using the RAM for household packaging.
Q3 2025 – July, August, September
July:
- Defra expected to release final modulated base fees, relating to household packaging. Payment for this will take place in 2026, relating to 2025 data.
September:
- Complete collation of your H1 2025 (January–June) data ahead of 1st October deadline, using the RAM for household packaging.
Q4 2025 – October, November, December
October:
- Submit your H1 2025 (January–June) data submission.
- Defra issues Local Authority Fee invoices.
What Producers Need to Do
Collect Accurate Data
Allocate sufficient time and resources to gather precise packaging data, ensuring compliance, cost-effectiveness, and enabling your Compliance Manager to provide optimal support.
Familiarise Yourself with RAM
Understand the Recyclability Assessment Methodology to evaluate household packaging recyclability accurately, ensuring accurate allocation of modulated fees.
Please note: Failure to use the RAM for assessing household packaging results in automatic ‘red’ classification, which means you will incur the highest fee.
Tips for a Successful 2025
Start Early
Initiate data collection promptly to minimise errors and allow for necessary adjustments.
Allocate Resources Wisely
With stricter deadlines and detailed requirements, assign adequate time for data collection, validation, and submissions.
Plan Ahead for RAM
Ensure your team comprehends the requirements around this methodology and allocates time to assess household packaging materials.
Clarity Resources
Clarity offers a wide range of support and resources to navigate 2025’s compliance requirements. We host regular expert-led webinars, helpful knowledge guides and up-to-date articles.
Comply with Clarity
If your business is not currently part of a compliance scheme, consider joining Comply with Clarity. Our expert team provides dedicated support and guidance to ensure you meet your packaging obligations with confidence. Contact us today to find out how we can help simplify compliance for your business.