Following notification to the WTO and EU in May, the regulations will now sit in Parliament for 40 days before implementation can begin
The UK Government has laid the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 before Parliament on 24 October, marking a key milestone in the implementation of extended producer responsibility (EPR) for packaging.
The Regulations provide the legislative framework for the new EPR system, mandating disposal cost payments from producers to cover the full net cost of managing household packaging waste. They establish requirements for producers to assess and report on packaging recyclability, while formally creating a Scheme Administrator to oversee fee modulation and payments to local authorities.
The legislation defines several classes of producers including brand owners, importers, distributors and online marketplaces. Large producers, those with annual turnover over £2 million and handling more than 50 tonnes of packaging, have already been required to register and report packaging data under existing regulations, which these new regulations will replace.
The regulations set out requirements for disposal fee payments from 2025, with these calculated by the Scheme Administrator based on the amount and type of household packaging producers place on the market, with fees modulated from 2026 based on packaging recyclability and environmental impact. The administrator will distribute payments to local authorities based on their costs of managing packaging waste, while assessing authority performance with the power to potentially reduce payments if services are deemed ineffective.
The Regulations set recycling targets for all packaging materials through to 2030. Plastic recycling targets begin at 55 per cent in 2025, rising to 65 per cent by 2030, while paper and board starts at 75 per cent in 2025, increasing to 85 per cent by 2030. Glass follows a similar trajectory from 74 per cent to 85 per cent, with aluminium moving from 61 per cent to 67 per cent, steel from 80 per cent to 85 per cent, and wood from 45 per cent to 50 per cent over the same period.
The Regulations aim to also maintain but strengthen the PRN/PERN system for demonstrating recycling compliance. From 2026, all reprocessors and exporters must register, with enhanced accreditation requirements, new sampling and inspection protocols, more detailed reporting obligations, and strengthened enforcement powers being introduced.
Several transitional arrangements are outlined in the regulations, including the requirement for small producers to register and report packaging data from April 2025, and the shift from shared supply chain compliance under the 2007 regulations to a single point of compliance for both recycling obligations and local authority waste management fees.
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How will the government and DMOs address the challenges of including glass in DRS while ensuring a level playing field across the UK?
There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.