pEPR

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.

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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?

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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.