Another RPS for Packaging EPR

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On October 9th, the EA have published another RPS – intervening to address the reduced availability of PRNs and PERNs for the 2026 compliance year.

Since the start of 2026, measures have been introduced to attempt to strengthen the integrity of the PRN system and tackle fraud and error.

These have included:

  • Stronger accreditation requirements for reprocessors and exporters.
  • Tighter export rules — PERNs can now only be issued when packaging waste arrives at the overseas reprocessing facility, rather than when it leaves the UK.

Unsurprisingly, these changes have reduced the number of accredited reprocessors and exporters in the system, extended the time taken to issue PERNs and reduced their availability. The result is that producers and compliance schemes face a real risk of being unable to meet their 2026 recycling obligations. Hence the RPS.

The New 2026 Position

For plastic, steel and wood, producers and compliance schemes meeting the conditions of the RPS will not face enforcement action if they achieve reduced percentages of their original recycling obligations:

🟢 Plastic: 83%

🟢 Steel: 92%

🟢 Wood: 90%

But note – meeting the conditions of the RPS is not the same as meeting the original statutory recycling obligation in full.

The regulators will recognise those complying with the RPS in a new category on the public register.

What Does This Mean for Businesses?

  • You must meet all of the conditions of the RPS to rely on it for compliance.
  • If you have to apply the RPS because you can’t achieve the original recycling targets – it will go on public record.

The EA’s full RPS is here Compliance with the packaging producer recycling obligations in 2026: RPS 383 – GOV.UK

EPR – Delays to the Need to Report Paper and Plastic Bags Data in England – RPS 330

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Yesterday the Environment Agency amended their Regulatory Position Statement (RPS) 330 for EPR.

Previously, the RPS related to producer obligations to collect and report data relating to nation of sale and self-managed organisational waste. Now it has been extended to cover paper and plastic bag data too.

This RPS delayed the introduction of self-managed organisational waste data collection until 1st January 2026 and reporting on or before 1 October 2026, and of nation of sale data collection until 1st January 2026 and reporting on or before 1 April 2027.

It now also delays the introduction of plastic and paper bags data collection until 1st January 2026 and reporting on or before 1 April 2027.

But don´t forget the small print “The Environment Agency will not normally take enforcement action against you if you do not comply with these legal requirements provided that your activity meets the description set out in this RPS”.

Read the full RPS here

Contact Us for help with your EPR data or Recyclability Assessments.

EPR Illustrative Fees for Year 2 Have now been Published – Big Changes Ahead

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Yesterday DEFRA published fee estimates for what large producers will be charged for year 2 of the EPR (2026-2027) per tonne of Household packaging, including Fee Modulation due to RAM.

Note – these are not confirmed but just an estimate to assist with budgeting. The precise fees for year 2 will be published in mid 2026 (once all of the 2025 data reporting has been finalised).

With the modulation factor being incorporated for the first time we already knew that 𝐑𝐄𝐃 𝐩𝐚𝐜𝐤𝐚𝐠𝐢𝐧𝐠 𝐰𝐢𝐥𝐥 𝐛𝐞 𝐜𝐡𝐚𝐫𝐠𝐞𝐝 +20%, however we did not know how much fee reduction GREEN packaging would be charged and now we do, and unfortunately 𝐆𝐑𝐄𝐄𝐍 𝐩𝐚𝐜𝐤𝐚𝐠𝐢𝐧𝐠 𝐰𝐢𝐥𝐥 𝐛𝐞 𝐜𝐡𝐚𝐫𝐠𝐞𝐝 𝐨𝐧𝐥𝐲 -9%.

𝐓𝐡𝐞 𝐊𝐞𝐲 𝐓𝐚𝐤𝐞 𝐇𝐨𝐦𝐞𝐬 𝐚𝐫𝐞 𝐭𝐡𝐞𝐬𝐞:

  • The Other categories (e.g. textile, cork etc) have seen a 15% decrease in base rate from £259 to £225 – however as most Other packaging will be RED rated an Other tonne will likely be £270All RAM rated GREEN packaging will get a 9% fee reduction
  • All RAM rated RED packaging will get a 20% fee increase
  • The wood base rate has increased by 60% from £280 to £450 – and as most Wood will be RED rated a Wood tonne will likely be £540
  • The Fibre-based composite base rate has increased by 14% from £461 to £525 – and as most Fibre-based composite will be RED rated a Fibre-based composite Tonne will likely be £630

We knew the fees would be increasing and now we have a bit more meat on the bones to help with budgeting. However, the key to greatly reducing your fees is in understanding your RAM #RecyclabilityAssessments.

Contact Us if you would like a demo of our Recyclability Assessment Tool and see why our clients are saying that it is so much simpler than anything else they´ve seen.

Full details of the Fees are available here.

Recyclability Assessment Supplementary Guidance Published

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Today DEFRA have published some Recyclability Assessment Supplementary Guidance to further clarify the Recyclability Assessment Methodology (RAM).

The Guidance addresses a number of issues that have been subject to some confusion, such as:

  • When your Recyclability Assessments should be reviewed
  • How Household packaging applies to online marketplace operators
  • How to deal with medical packaging
  • The role of Distributors in Recyclability Assessments
  • Assessing packaging with 2 or more components
  • Assessing labels
  • Take-back schemes
  • Chemical contaminants
  • And further specific clarifications for individual material types (including compostable packaging).

Read the full Recyclability assessment methodology: Supplementary Guidance.

Contact Us for further information or assistance with your Recyclability Assessments through our Recyclability Assessment Tool.

Extended Producer Responsibility pEPR Fees Explained

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PackUK have published a number of updates in recent days essentially summarising some policy documents, including pEPR Fees.

As a reminder these include:

How the fees will be calculated is complex. To understand how the Fees will affect what you pay under pEPR we have produced a brief webinar.

How Recyclability Assessments Will Affect Your pEPR Fees.

Watch below.

Contact Us for further information or assistance with your Recyclability Assessments through our Recyclability Assessment Tool.

Key Extended Producer Responsibility (pEPR) Documents now Available in Welsh

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Key documents relevant to extended producer responsibility for packaging (pEPR) published by PackUK have now been published in Welsh.

If you need access to either the 2025 Base Fees, the Fee Modulation Policy Statement or Interim Strategy in Welsh, these are all now available via the Government Extended Producer Responsibility Publication News Page

pEPR – EA Publish Another RPS – RPS 351

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pEPR RPS 351

The Environment Agency has published another regulatory position statement under the Extended Producer Responsibility (pEPR) regulations. RPS 351 relates to the definitions of fibre-based composite, and paper and board to be used by obligated organisations.

An amendment to the 2024 EPR regulations, due to come into force at the start of 2026, will amend and introduce definitions of fibre-based composite material and paper and board. As such, these two definitions have not yet been made into law.

The definitions are:

  1. Fibre-based composite material:  Packaging material which is made of paperboard or paper fibres, with one or more layers of plastic, and which may also have layers of other materials, to form a single unit that cannot be separated by hand, and is not in the ‘paper or board’ packaging category
  2. Paper or board: This includes packaging material which is within the description in sub-paragraph (i) of the definition of fibre-based composite material, “if the producer who supplies the packaging can provide evidence that its layer or layers of plastic are not more than 5% of the packaging material by mass”.


This RPS allows organisations to use these definitions in advance of the amendment regulations being made. This therefore allows organisations to report 2025 data in line with the forthcoming definitions and prevent the need to resubmit data at a later date to reduce administrative burden on bth producers and the Environment Agency.

Read the full Extended Producer Responsibility for Packaging (pEPR) fibre-based composite and paper and board obligations: RPS 351.

Confused by the requirements for Recyclability Assessments?

Visit our Recyclability Assessment Tool page for further information on our Tool or Contact us for a demo of our simple to use Recyclability Assessment Tool.

Recyclability Assessment Deadline Delayed – RPS 350

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As was probably always quite likely, the Environment Agency have now published a Regulatory Position Statement (RPS) to give large producers under the UK´s Extended Producer Responsibility Regulations for Packaging some breathing space when it comes to submitting their Recyclability Assessments (RA´s), that were originally due by October.

The RPS is quite clear that the legal deadline of October 2025 still stands, however they have stated that they ´will not normally take enforcement action against you if you do not comply´, providing that the RA data is submitted by 1st April 2026. Read the full text of the Extended Producer Responsibility for Packaging (pEPR) recyclability assessment obligations: RPS 350.

What this does mean however is that if, as a large producer, you decide to delay your submission until 1st April 2026, your disposal fees calculated in financial year 2026-2027 will be based on the data submitted in April 2026 and applied to the whole of the data reported in CY 2025. As opposed to your October submission being used for the first half year´s data submission and your April submission being used for the second half year´s data.

This does provide large producers with some much needed breathing space to organise their recyclability assessments. Need help with your Recyclability Assessments?

Visit our Recyclability Assessment Tool page for further information on our Tool or Contact us for a demo of our simple to use Recyclability Assessment Tool and let our simple software solutions take the pain away. Our mission is to simplify the complex.

Surprise Revision to The Recyclability Assessment Methodology (RAM)

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The Governments Recyclability Assessment Methodology (RAM) has already been amended. First published in December 2024, the RAM underwent minor amendments to a few typos in February of this year, but has since been amended significantly in April.

Despite it stating that ´Updates from version 1 (December 2024) are noted in the text´ – only whole requirements that have been removed are highlighted. There are other minor changes (word/phrase additions and removals) that have also been made and that are not highlighted.

With the first submission deadline of October fast approaching many organisations will already have started their assessments. These will now need to be revisited. Read the Recyclability Assessment Methodology v1.1.

If your organisation is obligated to undertake these recyclability assessments, let us take the pain out of keeping up-to-date with all these changes. Our bespoke tools keep on top of everything for you.

Visit our Recyclability Assessment Tool page for further information on our Tool or Contact us for a demo of our simple to use Recyclability Assessment Tool.

Recyclability Assessments – Everything You Need to Know

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The UK Government´s Extended Producer Responsibility (EPR) regulations for packaging have introduced a requirement that from 1/1/25 Large Producers (those with a turnover of > £2 million and which supply more than 50T of packaging per annum) must conduct Recyclability Assessments for all packaging that becomes Household Packaging and report these assessments by 1/10/25.

The aim of the requirements is to shift the cost of managing packaging waste from the taxpayer to the producer and to make producers responsible for the full lifecycle of their packaging, from design through to end-of-life disposal or recycling.

How to do Recyclability Assessments for the Regulations?

The Recyclability Assessments must follow the specific Gov.uk Recyclability Assessment Methodology (RAM). The methodology requires that each packaging component is assessed through the life cycle stages of classification, collection, sortation, reprocessing and application and will be assigned a Red, Amber or Green rating. These ratings will be applied to the EPR fees to be paid by the producer, therefore encouraging producers to improve the recyclability of their packaging.

  • Red: means the item is challenging to recycle, often due to problematic materials or designs.
  • Amber: means the item is recyclable but may need specialised collection or reprocessing.
  • Green: means the item is widely recyclable within the UK’s current systems.

The RAM is complex and requires in depth knowledge of your packaging components, the materials used within them, their design and detailed specifications from your suppliers.

Need Help with Your Recyclability Assessments?

Watch our brief video on An Introduction to Extended Producer Responsibility and Recyclability Assessments

Watch our brief video on How to Define Household Packaging

Watch our brief video on How to Determine Packaging Components and Material Types

With our bespoke tools we can help you to: brief your teams on what is required; understand the guidance; follow the RAM; complete the Recyclability Assessments for all your components; and report to meet your compliance deadlines with Certitude.

Visit our Recyclability Assessment Tool page for further information on our Tool or Contact us for a demo of our simple to use Recyclability Assessment Tool.