UK packaging EPR is active, fees are being charged, and from 2026 the cost of packaging will be directly linked to its recyclability. For skincare brands, the design decisions being made now will shape the financial picture for years ahead.
The information in this article is intended as general guidance only. Richmond is a packaging specialist, not a legal or regulatory adviser. For advice specific to your organisation's obligations under EPR, we recommend consulting a qualified professional or referring to the official Government guidance linked above.
The UK government has committed to achieving net zero carbon emissions by 2050. Extended Producer Responsibility is one of the regulatory mechanisms introduced to support that commitment, placing the full net cost of end-of-life packaging management on the businesses that bring packaging to market, rather than on local authorities and taxpayers.
The concept was first formally introduced in Sweden in a 1990 environmental policy report, which set out the principle that manufacturers should bear responsibility for the full lifecycle of their products, including recovery, recycling, and final disposal. The UK's framework builds on that logic, updated for current market structures and waste management systems.
The Extended Producer Responsibility regulations replaced the 2007 Packaging Waste Regulations, with the current framework contained in the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. The regulations apply to all UK organisations that manufacture, import, or supply packaging. Packaging is defined as any material used to contain, protect, handle, or deliver goods, including materials designed to be filled at point of sale.
The following criteria determine whether data must be collected and reported:
• You are an individual business, subsidiary, or group (does not apply to charities)
• Annual turnover is £1 million or more, based on the most recent financial accounts
• Responsible for importing or supplying more than 25 tonnes of packaging to the UK market in the previous calendar year
EPR is designed to create a more circular economy by shifting the financial responsibility for packaging waste from local authorities to the producers who generate it. The aim is to give producers a direct commercial incentive to design packaging that can be collected, sorted, and processed efficiently.
The scheme's core objectives:
• Producers fund the full net costs of collecting and recycling the packaging they place on market
• Reducing excessive packaging
• Increasing recyclability and reusability across packaging formats
• Improving the quality of material available for recycling
• Reducing packaging that ends up in street bins or as litter
For the latest guidance on your specific obligations, the Government's EPR resource is the most reliable reference point: https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do
Each organisation falls into one of two categories:
• Small producers (£1-2 million turnover with more than 25 tonnes of packaging, or under £1 million turnover with 25-50 tonnes) are required to record and report their packaging data annually.
• Large producers (more than £2 million turnover and more than 50 tonnes of packaging) carry more extensive obligations. These include reporting every six months, registration with a scheme administrator, payment of disposal fees, and environmental regulator charges. Large producers must also obtain Packaging Waste Recycling Notes (PRNs) or Packaging Waste Export Recycling Notes (PERNs) to demonstrate recycling obligations are being met.
In the first full year of fee liability, disposal fees are charged as a flat base rate per tonne of material placed on market. Plastic carries a base fee of £423 per tonne; glass £192 per tonne.
From the 2026-27 fee year, those rates will no longer be flat. Under the Recyclability Assessment Methodology (RAM), each packaging format receives a Red, Amber, or Green recyclability rating. Red-rated formats attract a higher fee; green-rated formats a lower one. The premium on harder-to-recycle packaging increases each year. Material and structural decisions being made in briefs now will have a direct effect on fee exposure in the years ahead.
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