PackUK, the official scheme administrator for the UK’s packaging Extended Producer Responsibility (pEPR) programme, formally launched on 21 January 2025.
As of November 2025, the organisation has completed most of its first operational year, providing global packaging professionals with an early view of how pEPR is functioning and what compliance will entail.
How PackUK has implemented pEPR so far
Since its launch, PackUK has established the governance structures needed to manage the four-nation UK system.
Committees for risk, audit, operational oversight and technical guidance have been put in place, while the Recyclability Assessment Methodology (RAM) was published in April 2025 to prepare producers for future modulated fees.
The first round of invoicing has begun based on 2024 packaging data. Base fees per material were published early in the year—£423/t for plastic, £196/t for paper/cardboard, £192/t for glass and £259/t for steel—providing producers with initial cost benchmarks.
Local authorities have started to receive payments to fund household collection and recycling services, marking the first tangible flow of funds from producers to councils.
Early effects on producers and the supply chain
Even in this partial first year, PackUK’s activities have highlighted the operational adjustments required for compliance.
Companies supplying more than 25 tonnes of packaging annually—or meeting the relevant turnover thresholds—must ensure they are registered, reporting accurately and keeping robust data.
RAM has already been introduced as a tool to assess recyclability, with outputs classed as green, amber or red. Although modulated fees will not apply until 2026, producers are now required to begin applying RAM assessments to understand where design changes could reduce future costs.
Several brands in the food and beverage sector have already started reviewing packaging materials and mono-material formats to prepare for modulation.
Preparing for modulated fees and the forthcoming PRO
The transition to modulated fees in 2026 makes RAM assessments and packaging design a direct driver of compliance costs.
PackUK also announced that the formal process to appoint a Producer Responsibility Organisation (PRO) will begin late in 2025, with an expected appointment in early 2026. The PRO will handle delegated functions such as reporting support and industry engagement, particularly for smaller producers.
Global suppliers and exporters should now prioritise: confirming registration and reporting obligations, completing RAM assessments, reviewing packaging design for recyclability, clarifying reporting responsibilities across the supply chain, and preparing finance systems for timely payments.
Early adoption of these practices will reduce risk and position companies to manage modulated fees effectively from 2026 onward.
What packaging professionals should take away
Although PackUK has not yet completed a full year, its first ten months have offered a live demonstration of how national-scale EPR can operate. The initial year has clarified the flow of fees, the importance of recyclability assessments, and the governance structures underpinning compliance.
For global packaging professionals, PackUK provides an early case study in regulatory implementation, showing how obligations, reporting and material choices are increasingly linked to cost and compliance.
To assist businesses, a practical UK pEPR readiness checklist for 2026 follows, summarising the key steps packaging, procurement, sustainability and finance teams should prioritise ahead of the introduction of modulated fees and the PRO.
