Introduction

A key objective of packaging EPR is to ensure all packaging in the UK is clearly labelled so consumers know whether they should recycle it. The goal is to boost correct recycling, improve capture rates, and reduce contamination.

When does it come into force?

Mandatory labelling was originally due to begin on 1 April 2027, requiring all primary and shipment packaging to carry ‘Recycle’ or ‘Do not recycle’ instructions. However, in September 2024 Defra removed the labelling provisions from the EPR statutory instrument due to complexities maintaining an open border in Northern Ireland.

Defra says this is a temporary step and remains committed to introducing mandatory labelling, aiming for a consistent UK-wide approach that may be aligned with upcoming EU packaging rules. Timelines and final requirements are therefore unclear. We recommend that producers continue using OPRL to ensure consumers understand how to dispose of packaging.

Who does it apply to?

Mandatory labelling will apply to brand‑owners, pack/fillers of unbranded packaging, importers, and first UK owners. There is no de minimis threshold - every organisation must comply, including those without EPR obligations.

Packaging distributors will need to provide recycling information to smaller businesses beneath the EPR de minimis that are not completing Recyclability Assessment Methodologies.

What is the labelling requirement?

Government has not yet confirmed the final labelling design, it may follow the familiar OPRL marks shown below, or may follow mandatory labelling set out under the EU Packaging and Packaging Waste Regulation. Previous guidance advised labels will need to be clearly displayed on all packaging, with exemptions for very small packs (under 25 cm²).