Our Packaging Lead, Shane Monkman, explores the benefits and challenges presented by UK Extended Producer Responsibility, drawing on his expertise and insights from London Packaging Week 2025.
The UK now has a functioning packaging Extended Producer Responsibility (EPR) scheme. The first round of data reporting for producers is complete, who received their inaugural invoices in October, and local authorities are set to receive their first payments in November. This begins the transformative journey of shifting the financial burden of packaging waste management and recycling from cash-strapped local authorities and taxpayers to producers and consumers, with the potential to stimulate the packaging circularity we need.
While this is a positive step, across the FMCG, retail, wholesale, drinks, and packaging sectors, the final push to launch EPR has brought many challenges, which producers were not shy about airing during this year’s London Packaging Week (LPW).
Challenges presented by EPR
Some of the challenges raised about EPR include the availability and quality of packaging specification data, the complexity of the Recyclability Assessment Methodology (RAM), and higher than anticipated fees. There is also concern within the alcohol and glass sectors about the financial impact on hospitality businesses of the way EPR applies to products that are used in both business and household settings. Media coverage has been quick to highlight these issues, with some UK food firms even branding EPR a “packaging tax”.
Among the frank conversations and debates at LPW, another key topic risked being overlooked. UK EPR is expected to raise more than £1.43 billion in fees to fund local authority waste and recycling services and pay for communications to influence consumer recycling behaviour. But the UK must ensure its version of EPR delivers more than just funding flows – it must drive improvements in both packaging design and council services.
For councils, the EPR scheme includes a performance improvement process intended to require improvements in authorities whose services are deemed “not sufficiently effective”, but the extent and speed of the change this can drive will be discovered as the scheme beds in.
It will need clear accountability and a coordinated system to drive infrastructure investment, capability improvement, and end-market development to support real improvements in circularity. Otherwise, the EPR scheme risks failing to leverage the potential benefits of the “producer pays” model.
Redesigning our future
From the packaging design side, tighter regulatory requirements from EPR (and the Packaging and Packaging Waste Regulation (PPWR) in Europe) make Design for Recyclability (DfR) a commercial and legal necessity for brands.
If implemented effectively, EPR should stimulate and reward innovative structural packaging design and formats that are not only recyclable but also incorporate higher levels of recycled content, helping to create stronger end markets and insulating producers from the volatility of virgin material prices. It must not, however, incentivise producers to switch from heavier but lower impact materials, such as glass, to lighter but more environmentally problematic ones unless the result is a clear overall environmental benefit.
A work in progress
The UK’s packaging EPR scheme is not a perfect solution and must evolve alongside the fast-changing packaging value chain. It must incentivise the material changes, innovations, packaging waste treatment, recycling capabilities, and local services we need. Lessons from early implementation are feeding into the newly announced PackUK Technical Advisory Committee (TAC) groups, which aim to refine recyclability assessment methodology (RAM TAC), efficiency and effectiveness (E&E TAC), and communications and behaviour.
Combined with companies’ own sustainability ambitions, EPR costs are becoming a catalyst for collective change. Producers that are able to improve recyclability and reduce material usage will thereby cut the fees for which they are liable – creating a clear commercial incentive for more sustainable design.
With modulated fees set to be introduced in 2026/27, non-recyclable or hard-to-recycle packaging will face even steeper charges, further increasing the pressure on brands. The unresolved questions of whether and how to bring litter and commercial waste costs within the EPR scheme have the potential to greatly increase the amount producers are required to pay in future. How DEFRA and PackUK respond to ongoing concerns about complexity, costs, and fund allocation will be pivotal to whether EPR proves effective in reducing the environmental impact of packaging over the months and years ahead.
To support organisations in this transition, Eunomia has partnered with packaging design agency Touch to launch a new packaging advisory service. Our upcoming free webinar on November 20th will explore how businesses across FMCG, retail, and the wider supply chain can design packaging that aligns with both PPWR and EPR requirements.