New UK Regulatory Framework for Packaging (Extended Producer Responsibility – EPR)
Topic: Packaging Materials

Date of publication: 01 April 2025
The UK's Extended Producer Responsibility (EPR) framework for packaging becomes fully operational, requiring cosmetic companies to register, report packaging data, and pay fees based on the "polluter pays" principle, shifting waste management costs from local entities to producers.

What’s new?

The UK’s Extended Producer Responsibility (EPR) framework for packaging reached full implementation on 1 April 2025, marking a fundamental shift from the previous Packaging Recovery Note (PRN) system.

Under EPR, cosmetic companies must now register accounts, report detailed packaging data, and pay modulated fees based on recyclability. The framework implements the “polluter pays” principle, transferring £1.7 billion annually in waste management costs from local entities to producers, with fees potentially 6-20 times higher than previous PRN costs.

Key provisions

Obligation Criteria

  • Supply chain responsibility: Single point of compliance typically falls on brand owners/importers
  • Annual turnover: £1 million or more
  • Packaging volume: >25 tonnes imported/supplied to UK market annually
  • Business type: Individual businesses, subsidiaries, or groups (excluding charities)

Producer Categories

  • Small Producers: £1-2 million turnover AND >25 tonnes packaging OR >£1 million turnover AND 25-50 tonnes packaging
  • Large Producers: >£2 million turnover AND >50 tonnes packaging

Reporting Requirements

  • Large Producers: Bi-annual submissions (April/October deadlines)
  • Small Producers: Annual submissions (April deadline)

Fee Structure (2025 Implementation)

  • Registration fees: Payable to environmental regulators
  • Local Authority Waste Management fees: Based on household packaging reported
  • Modulated fees: Higher costs for difficult-to-recycle materials (encourages recyclable materials and reduced packaging)

What now?

  • Immediate: Complete EPR account registration if not already done
  • October 2025: First fee invoices issued to Large Producers based on 2024 data
  • March 2027: Mandatory recycling labeling requirements (postponed from April 2026)
  • Ongoing: Implement Recyclability Assessment Methodology for packaging portfolio

References

The Packaging Waste (Data Reporting) Regulations 2024, UK Statutory Instruments Extended Producer Responsibility for Packaging: Government Response, DEFRA March 2022 EPR for Packaging.

other REGULATORY UPDATES

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Date of publication: 03/05/2022

Date of application: 01/12/2023

The Commission Delegated Regulation (EU) 2022/692 includes new or updated classification for 12 chemicals that may be used as cosmetic ingredients. Seven out of these 12 are now classified as carcinogenic, mutagenic or toxic to reproduction (CMR) and are banned from cosmetic products marketed in the EU.

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