All obligated large producers were required by law to submit their packaging data for the first half of the year – the period of 01 January 2025 to 30 June 2025.
This includes packaging volumes and recyclability classifications for household packaging under the Recyclability Assessment Methodology (RAM).
Those who failed to comply risk enforcement action and the possibility of late registration fees. They should contact their environmental regulator.
The data will be used to determine the modulated fees which will be paid by producers next year.
Under pEPR, all obligated producers are required to pay base fees to PackUK, the scheme administrator.
The first of these payments are expected to be invoiced this month, following the publication of final fee levels by Defra.
The previous deadline for data from 01 July 2023 to 31 December 2024 was 01 April 2025.
Small producers
While large producers are obligated to submit their packaging data six-monthly, small producers are only required to submit on a yearly basis.
The first deadline for this submission was 01 April 2025. Those who failed to submit should contact their environmental regulator.
The deadline for submitting 2025 data (1 January to 31 December) is 1 April 2026.
Fears surrounding pEPR costs
Yesterday (01 October 2025), the British Retail Consortium (BRC) warned that producers are likely to pass on up to 80% of the costs of pEPR to consumers.
Andrew Opie, Director of Food and Sustainability at the BRC, said: “Retailers support the polluter pays principle and are making significant changes to reduce and improve their packaging.
“But the packaging tax is also a multi-billion pound levy being paid by consumers during a cost-of-living crisis.
“Unless funds are spent transparently and effectively, EPR threatens to just be another burden on an already overtaxed industry with no tangible benefits for customers or the environment.”
‘Companies need to embrace data requirements’
John Redmayne, Managing Director of EPR compliance expert ERP UK, said: “From 01 October 2025, companies will start receiving their first invoices under the new Extended Producer Responsibility system. It’s a watershed moment, fundamentally changing how the UK funds packaging waste management.
“We’re talking about the transfer of approximately £1.5 billion in annual costs from local authorities to packaging producers. Think about it – for decades, households have funded collections through council tax. Now, the companies putting packaging on the market are picking up the tab for what happens to household packaging at the end of its life.
“This touches thousands of UK businesses, including manufacturers, retailers, importers. While the scale is significant, here’s what excites me: for the first time, we have genuine alignment between financial incentives and environmental good practice.
“Critically, companies using recyclable packaging that meets the new definitions will see lower costs next year. That creates real market drivers for sustainable packaging choices. We’re talking lighter materials, better recyclability, reduced environmental impact.
“The transition demands robust data collection and reporting to get cost allocation right. There’s now a public register where companies can verify their suppliers, and competitors are registered and contributing fairly. No hiding, no free-riding.
“While everyone’s focused on compliance and data accuracy right now – and rightly so – the longer-term benefits are transformational. This system will drive the packaging innovations that campaigners, government and progressive producers have been calling for.
“The change is here. Companies that embrace these data requirements and use the insights to optimise their packaging choices? They’ll be the winners in this new landscape.”
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