Fees
When will the information on the calculation of base fees and modulated fees be made available?
Final base fees are now available here.
How should businesses accrue for EPR fees?
Any trade from 1 April is obligated for fees, as per DEFRA/PackUK guidance, but businesses may want to check with their own accountants as per financial year set ups.
Who carries the obligation for imported filled packaging which is branded but where the importation is done independently of the brand owner and where there is no financial or licence arrangement in place with the importer?
The importer would be required to report this packaging in accordance with Regulation 18(3)(b). The brand owner would not report the packaging as Regulation 16(4)(b) stipulates that a brand owner is not a producer in this scenario.
More information can be found regarding responsibility for imported packaging in the Regulators’ Agreed Positions guidance (pages 28 to 30).
Data Reporting
When do I need to submit packaging data by?
Large organisations need to report data every 6 months April and October, next date being 1 October 2025.
Small organisations must collect and report their 2024 data by 1 April 2025.
How do I find out what data needs to be submitted?
Data that is required to be submitted can be found via the Gov website.
What is the purpose of the nation data reporting and when does nation of sale data need to be submitted?
Waste is a devolved policy. Under the UK’s Extended Producer Responsibility (EPR) scheme for packaging, nation data reporting ensures recycling rates can be tracked, and recycling targets set, at a nation-level.
Is there producer obligations around responding to request from retail customers? For either detailed product-level information on packaging e.g. material type, weight, recyclability, or details regarding our PPT licencing and payment.
EPR
- There is no obligation to share information with your customers.
PPT
- Show They’re Following the Rules: Be ready to give evidence of Plastic Packaging Tax (PPT) registration and payments if retailers ask.
RAM
Is the decision tree for the RAM available?
The decision tree is now available Recyclability assessment methodology: decision tree diagram - GOV.UK.
Does RAM apply to all packaging reported under pEPR, or just 'household' packaging?
RAM assessments are only required for packaging fitting the definition of Household Packaging. Household packaging is defined in Regulation 8. Guidance on how to determine whether packaging is household or non-household is available on Gov.uk.
Where does re-usable/refillable packaging fit in the RAM?
Reuseable and refillable packaging will still require a RAM assessment but will only be charged EPR fees the first time it is placed on the market.
Why is glass with a label is amber? When glass is recycled it is melted at very high temperatures and the paper label would burn off so surely this is a green given glass is easily recycled?
The reason for the amber glass output is that if the label covers over 60% of the surface area of the glass item it can cause secondary material loss, if the label covers less than 60% it is a green output (assuming it meets all other requirements for a green output).
Is this the final version of RAM?
DEFRA have made clarifications and minor amends to the RAM found here. This will be accompanied by a regulatory position statement.
The RAM will also be reviewed annually in July 2026 to ensure that it remains up to date with recycling rates and improving recycling infrastructure.
What are the impacts of the amber / red categories in the RAM?
The amended approach to fee modulation has recently been developed and was published alongside the final fees.
Amber fee is believed to remain at base fee, whilst red and green bonus and malus will be calculated as multiples of the base fee.
Are companies expected to report RAM assessment per SKU or packaging totals with associated categorisations (green, amber, or red)? How will the eco-modulation fees be assigned - per SKU or by packaging totals?
Where a packaging item has multiple components which are separable by hand these will require separate RAM assessments. Obligated producers are required to report the total tonnage for each material category across all the household packaging they place on the market with the relevant RAM output.
Is there any assessment on what percentage of products or tonnage of packaging material classified as recyclable under OPRL would be classified as Amber or Red under the new RAM?
Not at present - More information can be found through OPRL guidance on EPR.
Regarding accuracy - producers are working within "accurate as reasonably possible" but what is the guidance if businesses do not have all of the information for all products given the short time frames?
DEFRA intend to publish further guidance on this.
Do drinks containers which are not subject to disposal fees still need to be assessed through the RAM?
The RAM was published before the legislation for DRS had been passed. The legislation has now been laid and drinks containers within the scope of DRS do not require a RAM assessment, unless a DRS is not implemented by October 2027 and then EPR will fall as a backstop, and they will fall under EPR obligations.
Are producers required to provide evidence of RAM assessments? e.g. certification?
The requirement is to report the outcome of the RAM assessment by material, although Producers are required to keep supporting evidence for seven years as regulators may require this if the producer is selected to be audited.
More guidance on this will follow.
How will mid-year changes be accommodated and able to be factored into assessments? One example would be the introduction of flexible plastics collections at end Mar 2027.
Annual RAM and Guidance Review: The RAM is reviewed and updated annually, with changes published in July, for use in the following year’s assessments. This ensures recyclability assessments remain current with infrastructure and policy changes.
Producer Reassessment Duties: Producers must update recyclability assessments if packaging design or methodology changes. They report results every six months.
Annual LA Cost Assessments: The scheme administrator reviews Local Authority (LA) costs and collection capabilities annually, using the latest data by 1st November to set fees for the next assessment year.
Effectiveness Assessments: From 2028, LAs will be assessed on the effectiveness of their waste services. Improvements like flexible plastic collection will be reflected in these assessments.
Recalculations: If a material change occurs during the assessment year, the scheme administrator can recalculate producer fees or LA costs mid-year or post-year to reflect updated realities.
Labelling
What is the impact of the delay to labelling requirements likely to be?
It is expected that our labelling requirements will come in during 2028.
Advice is to continue with current voluntary labelling schemes for the time being (OPRL).
What is the long-term impact of alignment with the EU? Unintended consequences of dynamic alignment?
It is expected that the labelling requirements will come in during 2028. In preparing our regulations, we will review what is being proposed under the EU Packaging and Packaging Waste Regulation and explore the potential for consistency across our approaches.
We will seek to minimise the costs and complexity of the arrangements for those businesses trading across all these markets, while protecting our commitment to the importance of labelling as part of the overall objectives of these reforms.
Litter
When will the Scottish and Welsh Govts announce further details on ground litter obligations?
At present, the Scottish and Welsh Governments haven't shared full details about ground litter rules under EPR. However, both have reviewed and consulted on litter and fly-tipping enforcement, so new policies are expected soon.
Enforcement Models - Litter and flytipping offences - enforcement review: final report - gov.scot
Policy Interactions & DRS
How does material flow in Wales get measured to ensure compliance with EPR when in scope of a separate DRS scheme?
In Wales, waste is tracked through detailed analyses and data collection to meet EPR rules. This continues even alongside a separate Deposit Return Scheme (DRS). The Welsh Government stresses that clear, accurate data is key to shaping policy and enforcing the rules.
Residual waste infrastructure capacity note - GOV.UK
Does Welsh packaging in scope of DRS also fall under RAM?
In Wales, packaging covered by the Deposit Return Scheme (DRS) may also be assessed under the Recyclability Assessment Methodology (RAM) if it ends up in general waste. This overlap helps ensure all packaging is properly reviewed for how recyclable it is, no matter how it's disposed.
Extended producer responsibility for packaging: report packaging data - GOV.UK
Waste Collections & LAs
How will volume of waste collections be measured?
Waste collection volumes are measured through:
- Local Authority Reporting: Councils report how much waste they collect and how often.
- Standard Models: Tools like LAPCAP help estimate average collection volumes and frequencies using consistent methods.