The Chartered Institution of Wastes Management (CIWM) breaks down the recent joint policy statement by the Four UK nations on packaging extended producer responsibility.

On Thursday 27 February 2025, the Secretary of State for DEFRA, and Ministers in DAERA in Northern Ireland, Scottish Government and Welsh Government (‘the Four Nations’), published a Joint Policy Statement on pEPR.

The policy statement sets out the intended environmental effects of the pEPR policy, and how the policy will achieve those effects. More specifically, it covers the core governance documents the Scheme Administrator – PackUK – must publish in 2025, the outcomes PackUK will be expected to work towards, and the deliverables the Four Nations will expect in PackUK’s first year of operation.

The full Policy Paper can be accessed here, this Briefing Note summarises the key points.

The key intended outcomes of the Policy Paper

PackUK must act in accordance with the need to facilitate the achievement of the four key environmental effects set out in the policy paper:

• the use of environmentally sustainable packaging;
• the prevention of packaging becoming waste;
• an increase in the reuse of packaging, and in the quantity and quality of packaging materials recycled;
• a reduction in the packaging material placed on the market.

Core PackUK governance documents expected deliverables

The policy statement details two core governance documents; a strategy (to be published no later than June 2025) and an ongoing operational plan (updated annually no later than 28th February).

1. Strategy

PackUK’s strategy should contain:

• objectives, functions, and the outcomes it seeks to achieve;
• governance and delivery arrangements, and how these support the outcomes of pEPR;
• how PackUK intends to engage with those with a legitimate interest in the way it performs its functions;
• how PackUK intends to measure and report on delivery of its objectives and scheme outcomes.

2. Operational plan

PackUK’s operational plan should cover their:

• priorities for the coming financial year;
• forecasts of disposal costs of local authorities and for public information campaigns;
• approach to calculating disposal fees payable by liable producers;
• proposed public information and other communication activities in the operational year.

Key “Year 1” deliverables for policy measures

PackUK will be expected to deliver four key deliverables:

1. Producer base fees and modulation

PackUK should publish final base fees for the 2025/26 year no later than June 2025.

PackUK will be expected to publish a statement of policy on modulation as “soon as is practical” after its establishment and then review that policy at least every three years thereafter.

The Four Nations expect this first policy statement to be published alongside PackUK’s strategy, no later than June 2025, which should seek to:

• 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;
• articulate how modulation in particular will encourage the use of easier to recycle packaging and a move to reuseable alternatives;
• articulate how fees will support recycling at scale.

2. Local authority efficient and effective management of packaging waste

An estimate of payments that will be made to local authorities must be provided to local authorities as soon as reasonably practicable for the 2025 assessment year. For subsequent years, the Scheme Administrator must provide an estimate of payments no later than 1 November ahead of that assessment year.

3. Public information campaigns

PackUK must deliver public information campaigns to provide consumers and businesses with information about how to recycle, re-use and dispose of packaging, and prevent packaging from becoming litter.

4. Measuring and reporting on progress

In its Strategy, Packflow is required to set out how it will measure and report on delivery of its objectives and outcomes. The key performance indicators it will apply will be set out in its yearly Operational Plan.

In addition, the Four Nations expect PackUK to use the Strategy and Operational Plan to set stretching objectives, goals and performance standards that take account of expectations set out in this policy statement and deliver against both scheme outcomes and a quality service for businesses and local authorities who interact with them.

The Four Nations will monitor PackUK’s performance, including through their annual report, the first of which will be due by 30 September 2026 for year 1 of EPR for packaging, and each year thereafter.

Should PackUK fail to set suitably stretching objectives, goals or performance indicators, or deliver against them, the Four Nations will consider whether it is appropriate to rely on their powers contained in regulation 59 of the Packaging Regulations 2024 to formally direct them to take, or refrain from taking, specified actions in order to improve performance.

Further details and information about PackUK can be found here.

Information and general guidance on the pEPR regulations can be found here.

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