A statement from Defra, DAERA, Scottish Government, and Welsh Government has set out a laundry list of scheme administrator duties to make packaging extended producer responsibility operational, with June 2025 deadlines set for key governance documents.
The UK Government has published a joint policy statement outlining clear expectations for the Extended Producer Responsibility for packaging (pEPR) scheme administrator, PackUK.
The document, issued by the Department for Environment, Food and Rural Affairs (Defra), the Scottish Government, the Welsh Government, and Northern Ireland’s Department of Agriculture, Environment and Rural Affairs (DAERA), establishes detailed benchmarks for PackUK’s first year of operation, which several critical deliverables required by June 2025.
The scheme administrator must publish two governance documents to explain its approach to achieve the Four Nation’s goals: to promote the use of environmentally sustainable packaging, prevent packaging becoming waste, increase the reuse of packaging, and reduce packaging material placed on the market.
A Strategy, to be delivered in June this year, will define PackUK’s objectives, goals, governance arrangements, delivery arrangements, stakeholder engagement plans, and methods for measuring and reporting progress.
Although recruitment for the posts of Chief Executive and Chief Strategy Officer for PackUK started last week, a Defra spokesperson commented that ‘development of the strategy was already underway in the interim scheme administration team’, which would ‘be working together with the new team’ so there will not be a standing start.
Following the release of the Strategy, PackUK will then be required to release an Operation Plan each year by 28 February, which will include priorities for the coming financial year, forecasts of disposal costs, information on public communications, and its approach to calculating disposal fees.
Information on EPR modulated fees due by June 2025
Final base fees for 2025/26 must be published as part of the Strategy, with the statement noting that “the introduction of base fees will incentivise producers to improve design and place less material on the market, resulting in the prevention of packaging becoming waste."
The first modulation policy statement is expected alongside PackUK’s strategy by June 2025, and will be reviewed every three years thereafter.
The Four Nations outline specific requirements for this modulation approach, stating it should “drive producers to use household packaging that is easier to recycle or reuse, apportion fees to material groups in a way which supports the delivery of the intended outcomes of the scheme, factoring in disposal costs and improved environmental outcomes, including where feasible carbon impact."
Additionally, the modulation policy should "articulate how modulation in particular will encourage the use of easier to recycle packaging and a move to reusable alternatives, and in addition, articulate how fees will support recycling at scale."
To support this transition, PackUK must develop a recyclability assessment methodology, which will provide a standardised method for producers to assess the recyclability of packaging and inform on modulated fees.
Local authority payments and service assessment
The new scheme administrator will also be responsible for calculating and distributing payments to local authorities for the collection and disposal of household packaging waste.
It will need to consider "the disposal costs which a local authority would incur if it were providing an efficient waste management service, which is a service where costs are as low as reasonably possible, taking into account any other factors specific to that authority, while supporting the requisite scheme outcomes."
In November 2024, the Government advised that the assessment of local authorities' costs for managing packaging waste would be determined through the Local Authority Packaging Cost and Performance Model (LAPCAP). This model calculates the net efficient waste management costs by using LA-specific data (such as tonnages from Waste Data Flow) alongside comparative data from similar authorities, with revenue from recyclate sales explicitly deducted from the final payment amount.
The key metrics used include collection frequency, rurality, proportion of flats, deprivation levels, country, authority type, communal collection rates, collection scheme type, and tonnes collected per household. Local authorities are grouped based on these characteristics to determine comparable cost figures. Material-specific income is calculated using the WRAP Materials Pricing Report and netted off against costs—reflecting the definition of "net efficient disposal costs" as the efficient disposal costs less the expected income from sale of recyclable packaging. The model also incorporates national average gate fees and makes adjustments for recycling credits, collectively aiming to capture the efficient costs an authority would incur while accounting for both local conditions and revenue generation.
As part of the Operational Plan, the Scheme Administrator will produce further guidance on the methodology and procedure it will use, and the factors it will assess, to determine waste management efficiency.
Payments to local authorities are expected as soon as reasonably practicable for the 2025 assessment year, and by 1 November for subsequent years.
While formal assessment of local authority effectiveness is not required until 2028, the Four Nations expect the scheme administrator to begin these assessments earlier where sufficient data exists, "to ensure that local authorities are given early support and assistance to improve performance where this is possible."
Public information campaigns to encourage recycling
The Strategy will set out PackUK’s plans for public information campaigns to provide consumers and businesses with information about how to recycle, re-use and dispose of packaging materials.
Specific campaigns and communication activities proposed for the coming year will be set out in the Operational Plan, and should be tailored to each nation.
PackUK is expected to outline how it intends to measure and report on the delivery of its objectives and outcomes in the Strategy. This document, as well as the Operational Plans, will also set stretching goals and performance standards.
The Four Nations will monitor the Scheme Administrator’s performance through its annual report, the first of which is due by 30 September 2026.
Scheme administrator checklist
Key first-year requirements for PackUK, which launched as scheme administrator on 21 January 2025, include:
- Outline its objectives, functions, governance arrangements, and measurement methods by June 2025
- Publish final base fees for 2025/26 by June 2025
- Publish a statement of policy of fee modulation by June 2025
- Set out plans for public information campaigns by June 2025
- Update the recyclability assessment methodology
- Provide guidance on methodology for assessment local authority efficiency
- Provide payment estimates to local authorities as soon as practicable
- Establish stretching objectives and key performance indicators
- Publish an Operation Plan by 28 February 2026 with priorities for the coming financial year
- Prepare for the first annual report due September 2026
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