Policy roundup: reporting easements, PPT reforms and DRS producer fees

A number of significant policy updates have emerged in recent weeks, affecting packaging EPR reporting, Plastic Packaging Tax (PPT) compliance, the future rollout of flexible plastic collections in England, and preparations for the UK Deposit Return Scheme (DRS).  

EPR reporting easements extended through RPS 330 

The Environment Agency has updated Regulatory Position Statement (RPS) 330, extending reporting easements for several packaging EPR data requirements. Published on 25 August 2026, the RPS delays the introduction of nation data, self-managed organisational waste data, and plastic and paper bag data collection until 1 January 2028. Corresponding reporting deadlines have also been pushed back to 2028.   

According to the Environment Agency, these requirements currently have no bearing on producer disposal fees or recycling obligations, and delaying them will reduce unnecessary reporting burdens on producers, compliance schemes and holding companies. The regulator also notes that nation-specific data will have limited value until other forthcoming reforms are in place.  

What this means for producers: Businesses can continue to benefit from reduced reporting requirements in these areas, but should be mindful that they are a still a requirement within the EPR regulations.  

DRS producer fees announced ahead of scheme launch 

Exchange for Change has announced the intended producer fee structure for the UK Deposit Return Scheme, providing drinks producers with greater clarity as preparations continue ahead of the scheme's October 2027 launch.  

Following consultation with industry, producer fees for all eligible drinks containers will be set at 0p for the first 15 months of the scheme, covering October 2027 to December 2028. Based on current forecasts, fees are then expected to increase to 0.6p per unit for aluminium and steel containers and 2.3p per unit for PET containers from January 2029. Exchange for Change has stated that the figures will be reviewed, validated and reconfirmed in May 2027.   

The organisation says the phased approach is intended to support businesses during the early stages of implementation while maintaining the long-term financial sustainability of the scheme. Producer fees will continue to be reviewed annually after launch.   

What this means for producers: While the fees are not yet final, the announcement provides an early indication of the likely costs associated with DRS participation and should help affected businesses with budgeting and implementation planning. 

HMRC publishes mass balance guidance for Plastic Packaging Tax 

HMRC has published long-awaited guidance setting out how businesses can prepare to use a mass balance approach for Plastic Packaging Tax from 1 April 2027. The approach will allow chemically recycled plastic to contribute towards the 30% recycled content threshold used to determine whether PPT is payable.  

The guidance confirms that use of mass balance accounting will be optional. However, if businesses do not use an approved mass balance approach, chemically recycled plastic will be treated as virgin plastic for PPT purposes. HMRC has also published accompanying minimum certification requirements, setting out how certification schemes, certification bodies and businesses in the supply chain must operate.  

All businesses involved in a certified supply chain, from chemical recyclers through to packaging manufacturers, will need to meet certification requirements and maintain supporting records, certificates and attribution declarations.  

What this means for producers: The guidance provides greater certainty for businesses investing in chemical recycling and could help expand the range of recycled content options available to packaging manufacturers. Producers considering chemically recycled plastic should begin discussing certification requirements with suppliers ahead of implementation in April 2027. 

Pre-consumer waste to be excluded from recycled content calculations 

Alongside the mass balance guidance, HMRC has updated its existing PPT guidance to confirm that reprocessed pre-consumer plastic waste will no longer count as recycled content from 1 April 2027.   

The updated guidance explains that pre-consumer plastic waste can currently contribute towards recycled content calculations, but only until 31 March 2027. After that date, businesses will no longer be able to rely on these materials when determining whether packaging meets the 30% recycled content threshold. 

What this means for producers: Packaging manufacturers currently relying on production waste or internal reprocessing streams to meet PPT requirements should review their recycled content strategies and assess whether additional post-consumer or chemically recycled material may be required from April 2027 onwards. 

Flexible plastic collections delayed until 2030 

DEFRA confirmed its intention to defer mandatory collections of plastic films and flexible packaging from households and workplaces in England until 1 April 2030 last month. 

While the delay extends the timeframe for implementation, discussions continue on how local authorities already collecting these materials should be supported through packaging EPR payments. 

As a result, PackUK is currently considering how payments should be assessed for local authorities that have already introduced collections, or plan to do so during 2027/28. DEFRA also indicated that a new Plastic Film Forum is expected to launch in autumn 2026, bringing together stakeholders to focus on collections, sorting, recycling and end markets. 

What this means for producers: The delay provides more time for infrastructure development but also prolongs uncertainty around the availability of recycled flexible plastics. For producers with commitments linked to recycled content or packaging recyclability, progress on collections and processing capacity will remain a key area to watch. 

If you want have any questions on these updates please contact us at info@ecosurety.com.