Guide

UK pEPR, Plastic Packaging Tax and Simpler Recycling — the producer compliance stack

The UK has rebuilt its packaging-waste regime. The legacy Producer Responsibility Obligations (Packaging Waste) Regulations 2007 with the PRN/PERN tradable certificate system is being replaced by Extended Producer Responsibility (pEPR) — full producer payment of local-authority household-packaging collection costs, with fees calculated on a per-tonne per-material basis and modulated by recyclability (RAM, Recyclability Assessment Methodology). pEPR data reporting began April 2023, fee invoicing started October 2025. The Plastic Packaging Tax (PPT) at £223.69/tonne (2025/26 rate) applies to plastic packaging components manufactured in or imported into the UK containing less than 30% recycled plastic content, threshold 10 tonnes/year. The Deposit Return Scheme (DRS) for single-use drinks containers launches October 2027 in England, Northern Ireland and Wales; Scotland's separate DRS has been postponed. Simpler Recycling standardises household collection from 2026.

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The UK packaging stack — pEPR, PPT, DRS, Simpler Recycling

Layer 0 is the Producer Responsibility framework: an obligated producer is one with >£1M relevant turnover and >25 tonnes of packaging handled (small producers: £1M-£2M and 25-50 tonnes — data only; large producers: >£2M and >50 tonnes — data and fees). Layer 1 is pEPR data reporting via the DEFRA Report Packaging Data service, bi-annual, segmented by material (paper/card, plastic, glass, steel, aluminium, wood, fibre composites, other) and stream (household/non-household, drinks containers). Layer 2 is the pEPR fee — large producers pay PackUK (the Scheme Administrator) a per-tonne fee that funds local authorities, modulated by RAM recyclability rating (red, amber, green). Layer 3 is the Plastic Packaging Tax — separate from pEPR, HMRC-administered, levied on plastic components with <30% recycled content. Layer 4 is DRS, launching October 2027 (England, Wales, NI) for in-scope single-use drinks containers with a 20p deposit. Layer 5 is Simpler Recycling — standardised household collections from March 2026.

pEPR fees and the Recyclability Assessment Methodology (RAM)

pEPR base fees per material (illustrative DEFRA 2025/26 indicative rates): plastic ~£485/tonne, glass ~£240/tonne, paper/card ~£196/tonne, aluminium ~£266/tonne, steel ~£305/tonne, wood ~£319/tonne, fibre composites ~£455/tonne, other ~£280/tonne. Rates finalise quarterly and are recalculated based on actual local-authority cost data. Fee modulation by RAM rating starts 2026 — RAM-Red components pay a multiplier above base, RAM-Green components pay a discount. RAM rating is based on collection systems availability, sortation compatibility, reprocessing infrastructure and contaminant-free design. Components must be assessed under the DEFRA RAM rules; brand owners hold the RAM evidence. Online marketplaces have separate obligations for empty packaging supplied with goods.

Plastic Packaging Tax — the 30% recycled content threshold

The Plastic Packaging Tax (Finance Act 2021, in force April 2022) is levied on plastic packaging components manufactured in or imported into the UK that contain less than 30% recycled plastic content by weight. Rate: £223.69/tonne for 2025/26. Threshold: 10 tonnes of finished plastic packaging components per 12-month period. Quarterly HMRC return. Recycled content evidence: documented chain-of-custody from a recycler with mass-balance or segregated approach. Bio-based, biodegradable and compostable plastics do NOT count as recycled. Components ≥30% recycled content are exempt; components <30% pay tax. Group registration available for connected entities. Secondary liability extends to business customers who knew or should have known PPT was not properly accounted for.

Deposit Return Scheme — October 2027 launch

DRS for England, Wales and Northern Ireland launches October 2027 (postponed from earlier dates). In-scope: single-use drinks containers (PET plastic, steel, aluminium) 150ml to 3 litres; glass excluded from EWNI scheme (Scotland's separate scheme included glass — Scotland's DRS is currently postponed). Deposit: 20p (final rate to be confirmed). Producer obligations: register with the Deposit Management Organisation, mark containers with the DRS logo, fund the scheme. Retailers >100m² must operate return points. Compatibility with pEPR — DRS-scope containers shift from pEPR fee to DRS funding. Hospitality and on-trade arrangements remain in scope with simplified processes.

Simpler Recycling — standardised collections from 2026

DEFRA's Simpler Recycling standardises household waste collections across England from March 2026: every household to have collection of paper and card, plastic, glass, metal, food waste and garden waste (separately or co-mingled per local authority choice). Weekly food waste collection becomes standard. The reform supports pEPR cost transparency and RAM ratings — materials with widely-available collection infrastructure can score RAM-Green. Brand owners benefit from collection harmonisation reducing material-segregation complexity. Workplace and business waste separation requirements run in parallel from March 2025.

Practical readiness — building for the UK packaging regime

Build a per-SKU packaging master with component-level material, weight, recycled-content evidence and RAM rating. Wire pEPR bi-annual reporting and PPT quarterly returns from the same data — not parallel data entry. Run packaging-redesign programmes against pEPR fee impact: shift fibre-composite to mono-material card, replace black plastic with detectable colours, replace PVC labels with PET, increase recycled content above 30% to escape PPT. Track DEFRA fee rate updates quarterly. Plan DRS registration ahead of October 2027 for in-scope drinks brands — relabel artwork, packaging-component changes, on-pack DRS logo and barcode requirements take 12-18 months of lead time. Treat Scotland separately on DRS pending re-launch dates and timing.

Where this lives in V5 Ultimate

The clauses above aren't theoretical — every one maps to a shipped module and an industry profile. Jump to the parts of the product that turn this guide into evidence on a Monday morning.

Modules that do the work

Supplier portal

Document control

Quality Management

Industries this hits hardest

Consumer products Food & beverage Plastics & resins Cosmetics & personal care

Frequently asked

What replaced PRN/PERN?

pEPR replaced the PRN/PERN tradable-certificate compliance route. Under PRN, producers met obligations by buying recovery/recycling notes from accredited reprocessors. Under pEPR, producers pay a per-tonne fee to PackUK that funds local-authority collection. Producers no longer manage PRN trading. The compliance scheme registration model is gone; producers register directly via DEFRA's Report Packaging Data service.

How is recycled content evidenced for PPT?

HMRC accepts certified chain-of-custody evidence: ISO 14021 self-declared, mass-balance with audited reconciliation, segregated approach with batch records, or third-party schemes (RecyClass, ISCC PLUS). Supplier certificates must trace recycled content from waste source through reprocessing to the packaging component. Documentation retained 6 years. Audit risk concentrates on mass-balance claims without robust reconciliation.

Does compostable plastic count as recycled for PPT?

No. The PPT recycled-content definition counts only post-consumer or post-industrial recycled plastic. Bio-based plastics from renewable feedstock (PLA, bio-PE), biodegradable plastics and compostable plastics do not count as recycled content even if they offer end-of-life benefits. They pay the same PPT rate as virgin plastic when <30% recycled content.

Are online marketplaces obligated producers?

Yes — for empty packaging supplied with goods to UK consumers by non-UK sellers, the online marketplace is the obligated producer under pEPR. For UK-established sellers, the seller is the obligated producer. The marketplace versus seller-of-record split must be clear in seller contracts. UK importers of finished goods from non-UK suppliers are the obligated producers for the goods packaging.

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