The amendments introduced a series of technical and operational changes designed to refine the scheme, which launched in January 2025.
Expected to come into force from January 2026, the amendments addressed issues identified during pEPR’s first year of operation, including material classifications, corporate restructuring and the administration of producer obligations.
PackUK set out its expected pEPR timeline through to 2030 in its Recyclability Assessment Methodology (RAM) Roadmap 2025–2030 last month, in October 2025.
Packaging definitions
A key technical adjustment concerns the definition of “fibre-based composite material”, which will align with the RAM.
The change specified that the term refers to packaging made of paperboard or paper fibres with one of more layers of plastic that cannot be separated by hand.
Fibre-based composite packaging where the plastic layer accounts for less than 5% of the total weight will now be reported under the paper/board category rather than as a composite material.
In addition, PackUK will gain authority to expand the criteria for modulated fees, ensuring that costs can reflect whether packaging is “reasonably necessary” and not excessive for its intended purpose.
Closed loop collection and recycling
For the first time, producers operating closed loop collection and recycling systems will be able to offset the tonnage they collect and recycle from their EPR obligations.
Under the provisions, producers may report closed loop packaging waste separately, provided they collect food-grade plastic household packaging directly, ensure the waste is recycled without mixing with materials from other producers and hold evidence that the waste has been reprocessed into food-grade plastic materials.
Louisa Goodfellow, Policy Manager at Ecosurety, commented: “Ecosurety is pleased to see several constructive updates in the newly laid amendments to the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.
“Notably, the recognition of closed loop recycling systems for food-grade packaging, incentivising circular economy practices and rewarding businesses who are funding the reprocessing of hard to recycle materials.”
Clearer guidance on corporate mergers has also been provided, with the amendments specifying that the resulting body or a merger will be treated as a large producer is either of the merged bodies was a large producer.
Producer Responsibility Organisations
PackUK has been given the power to appoint one or more Producer Responsibility Organisations (PROs).
These industry-led bodies may be authorised to perform certain functions on behalf of PackUK or to provide advice and recommendations on the scheme’s operation.
In July 2025, it was announced that Valpak, the Packaging Scheme Forum, and a joint bid from the Industry Council for Packaging and the Environment (INCPEN) and the Food and Drink Federation (FDF) were taken through to the next round of the PRO appointment process.
Before appointing a PRO, PackUK must obtain consent from the four UK nations.
Applications for PRO status are now open, with suitability to be assessed based on industry support, value for money and past performance in similar roles.
Goodfellow added: “This delegation allows for greater industry involvement in the administration and shaping of EPR as it develops, helping to ensure that the system reflects practical realities.
“However, as the regulatory landscape continues to evolve, it will be crucial that producers receive timely and clear guidance on any changes to reporting requirements or other aspects to the system that these amendments bring about.”
Interested in the latest insights, expert guidance, and practical strategies to navigate the new packaging EPR regulations? Come along to The EPR Conference on 12 November 2025 in London. Find out more and buy tickets here.
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