Extended Producer Responsibility Is Now Live: Here's What Changes

What Is Extended Producer Responsibility?

Extended Producer Responsibility (EPR) is a policy approach that makes producers financially and operationally responsible for the end-of-life management of the products they place on the market. In the context of packaging, this means that the companies whose products are wrapped in plastic, glass, metal, or card are now required to fund the collection and recycling of that packaging.

The UK's EPR for packaging scheme came into force in April 2025, representing the most significant reform to waste funding in a generation. Previously, local authorities bore the majority of the cost of managing household packaging waste. Under EPR, that cost shifts to producers, creating a direct financial incentive to reduce packaging and improve recyclability.

Eco-Modulated Fees: The 2026 Development

The introduction of eco-modulated fees in 2026 takes EPR a step further. Rather than a flat fee per tonne of packaging placed on the market, producers now pay rates that vary based on how easy their packaging is to recycle.

Materials that are widely collected and have established recycling markets, such as clear PET bottles or aluminium cans, attract lower fees. Materials that are difficult to recycle, contaminate recycling streams, or have limited end markets, such as black plastic, PVC, or multi-layer laminates, attract significantly higher fees.

This creates a direct financial incentive for brands to redesign their packaging. A company that switches from a multi-layer laminate pouch to a mono-material alternative will see its EPR fees fall. The policy is, in effect, using the fee structure to drive upstream design change.

What This Means for the Supply Chain

For large consumer goods companies, EPR compliance is now a significant cost line. Many will be investing in packaging redesign programmes, working with suppliers to switch to more recyclable materials, and engaging with the Producer Responsibility Organisation (PRO) appointed to manage the scheme.

For smaller producers and importers, the compliance burden can feel disproportionate. The scheme requires detailed data on packaging placed on the market, which demands new internal systems and processes. Support for smaller businesses navigating compliance will be essential.

For retailers, EPR creates pressure to work with suppliers on packaging reduction and to communicate clearly with consumers about what can and cannot be recycled. The 'Recycle Now' labelling system is expected to become more prominent as a result.

The Bigger Picture

EPR for packaging is an important step, but it is not sufficient on its own. It addresses the cost of managing packaging waste, but it does not directly reduce the volume of packaging produced. For that, we need complementary policies: mandatory packaging reduction targets, reuse and refill requirements, and investment in alternative delivery systems.

We have long argued that recycling, while important, is a downstream intervention. EPR is a more upstream tool, but the most powerful interventions are those that prevent waste from being created in the first place. The Circular Economy Growth Plan signals that the government understands this. The question is whether the policy framework will follow.