Written on: April 1, 2025 by Patrick Heskins
Packaging waste is a political “hot potato” in most major economies. For many years, the UK has had a Packaging Waste Recovery Note system (PRNs) that was designed to pay for the cost of recycling. As of Jan. 1, 2025, the UK has introduced the Packaging Extended Producer Responsibility (pEPR) regulations that establish new requirements on companies placing packaged goods, and in some cases empty packaging, on the UK market.
pEPR creates a “disposal fee” to cover the full costs for the collection, sorting and, where recycling is not possible, disposal of packaging waste. Currently, UK local authorities pay these costs from income tax. Recycling costs will still be paid by the PRN system.
The pEPR disposal fees will also include the cost of managing litter, promoting recycling and other enforcement activities. In short, pEPR will transfer the costs incurred for recovering waste packaging, and making it suitable to be reprocessed, to the companies who place it on the market.
Reporting requirements
UK pEPR requires companies to report data on the packaging they place on the UK market each year if they have an annual turnover greater than £1 million and were responsible for importing or supplying more than 25 tonnes of packaging to the UK market.
Obligated companies are either marketers of a brand’s products, those who pack or fill for others, or those who import or supply empty packaging or packaged products into the UK. Companies that meet these criteria are divided into three groups:
1. Large Producers: Companies with an annual turnover of more than £2 million that supply or import more than 50 tonnes of packaging in the UK per year. These companies must report details of what they place on the market twice a year and pay pEPR fees.
2. Small Producers: Companies with an annual turnover of between £1 and £2 million that supply or import between 25 tonnes and 50 tonnes of packaging in the UK per year. These companies must annually report details of what they place on the UK market by April 1 of the following year. They do not need to pay a pEPR fee.
3. Others: Companies with an annual turnover below the £1 million and 25 tonnes threshold do not have to report any data on packaging materials but may have to report on and pay pEPR fees for the packaging and components that they supply to businesses exempted from paying the disposal fee.
Recyclability Assessment Methodology
The pEPR regulations require producers of packaging to assess the recyclability of their packaging using a new Recyclability Assessment Methodology (RAM) to understand if the packaging is recyclable in the current collection, sorting and reprocessing systems. The outcome will be a traffic light system:
• Red: A challenge for recycling
• Amber: May require specialized collection
• Green: Widely recycled within the current infrastructure
Aerosol dispensers will be required to undergo assessment using the RAM to determine if they can be recycled. Currently, aerosol dispensers will be classed as “Green: Widely recycled.” However, as collection and sorting practices change, this situation will need to be reviewed.
From 2026, the RAM will also be used to modulate pEPR fees. Modulation is where the pEPR fee for a package format is adjusted to reflect its ease of recycling.
Future developments
Final fees for pEPR will be issued in October 2025. Until then, UK Government has issued “illustrative fees” that, for the main materials used in aerosols, show the following costs:
• Aluminum: £435 per tonne or 1.3p for a 30g aluminum aerosol container
• Steel: £305 per tonne or 2.0p for a 65g tinplate aerosol container
• Plastic: £485 per tonne or 0.7p for a 15g plastic overcap
From 2026, the pEPR fees will vary depending on how easily the packaging type and material, in the case of plastic, can be recycled. The pEPR fee will be higher than the base fee if the packaging or material is deemed harder or more costly to recycle as determined by the RAM.
For aerosols, especially aluminum aerosols, the diversion of beverage containers from curbside collection may result in higher collection and sorting costs due changes in the process. This is due to the smaller amount of aluminum packaging being collected from curbside and an increased risk from greater numbers of aerosols in the waste, requiring additional safety equipment and processes. SPRAY
