2025 in review - a packaging policy round up

2025 has been a pivotal one for packaging producers under Extended Producer Responsibility (EPR), with significant regulatory changes and increasing obligations shaping compliance.  

New reporting requirements and the first round of Waste Management Fees (WMFs) meant that producers had to adapt quickly to evolving regulatory responsibilities and prepare for future developments. Here’s a round up of the changes we experienced in 2025.

Key updates in 2025 - Finalised Base Fees and Cost Certainty 

PackUK confirmed the final EPR base fees for packaging supplied in 2024, giving producers long-awaited clarity on expected costs ahead of invoicing, which began in October. While most material categories saw reductions from earlier estimates, fibre-based composites experienced a slight increase. Glass packaging costs notably dropped, although sector concerns remained due to the weight-based nature of the fee setting process. The long-term effects for the glass industry remain to be seen. 

Fee Modulation Framework Announced 

The fee modulation framework – applicable from 2026 onwards – was also published. It was confirmed that from 2026 fees will be modulated based on recyclability, as determined by the Recyclability Assessment Methodology (RAM). Packaging rated ‘red’ (least recyclable) will incur costs with escalating multipliers: 

• 2026: 1.2x base fee 
• 2027: 1.6x base fee 
• 2028: 2x base fee 

Revised and increased reporting requirements 

All packaging supplied in 2025 was reported under the main EPR statutory instrument, as opposed to the previous data reporting regulations. This meant some revised reporting rules, including for instance around the definition of drinks containers and shipment packaging, plus new conditions for brand owners. 

However, the most significant increase to the data obligations by far was the introduction of the RAM. The finalised methodology was released in late 2024, and reissued in April of this year. The substantial amount of additional packaging data collection the RAM constituted led to the Environment Agency releasing a Regulatory Position Statement (RPS), granting producers an exemption for reporting of H1 2025 RAM data. This RPS does not apply to H2 figures, meaning all large organisations must be prepared to submit accurate RAM ratings by April next year.  

Draft amendments laid before parliament 

In late 2025, the UK Government introduced amendments to the EPR regulations expected to apply from January 2026, pending parliamentary approval, these include the: 

• Appointment of a Producer Responsibility Organisation (PRO) to oversee EPR operations 
• Ability for producers to offset additional categories of collected and recycled material via ‘self-managed consumer waste’ reporting 
• Expanded criteria for potential fee modulation, considering packaging necessity and excess 
• Revised definition of fibre-based composites to align with RAM  

What’s coming in 2026? 

Next year promises further requirements for businesses obligated under EPR:  

Additional data collection requirements - Producers will need to start collecting and reporting nation of sale and self-managed organisation waste due to the lifting of an additional RPS, alongside sales of single-use carrier bags in England. 

Introduction of Modulated Fees - The first invoices reflecting recyclability-based modulation will be issued, making packaging design choices more financially significant than ever. 

As we move into 2026, businesses should prioritise accurate data collection and recyclability improvements to mitigate rising costs under modulation.

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