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.

Linkedin Instagram Facebook

other REGULATORY UPDATES

Regulation (EU) 2022/1531 – OMNIBUS ACT V – applicable as of 17 December 2022

Ingredients: METHYL SALICYLATE, SODIUM HYDROXYMETHYLGLYCINATE, DBMC, MIBK

Date of publication: 15/09/2022

Date of application: 17/12/2022

The European Commission has published the Commission Regulation (EU) 2022/1531, which amends the Regulation (EC) No 1223/2009 as regards the use in cosmetic products of certain substances classified as CMR, by adding new entries to Annex II and Annex III and revising an entry in Annex V.

Read More »

French Anti-Waste Law – Impact in Cosmetics Packaging and Labelling

PACKAGING WASTE MANAGEMENT

Date of application: 01/01/2023, with a transition period until 09/03/2023 for packaging produced or imported before 09/09/2022.

The Loi relative à la lute contre le gaspillage et a l’économie circulaire (Anti-Waste for a circular economy) has come officially into force in France in 2020. From January 2023 the requirements of the law became mandatory, including specific symbols on the packaging or labelling of cosmetic products.

Read More »
Any REGULATORY QUESTION?
E-mail

SCCS Revision of the Scientific Opinion on Vitamin A

Ingredients: RETINOL, RETINYL PALMITATE, RETINYL ACETATE, RETINYL LINOLEATE, RETINAL

Date of publication: 25/10/2022

The Scientific Committee on Consumer Safety has issued a final version of the Scientific Opinion on Vitamin A, concluding that exposure to Vitamin A derived from cosmetics can be a concern for higher exposure consumers, and since cosmetics alone do not exceed the upper limit the SCCS cannot suggest maximum concentration limits that take into account contributions from other sources.

Read More »

UK Responsible Person Labelling Deadline Extension

RESPONSIBLE PERSON

Date of application: 31/12/2025

The UK Office for Product Safety and Standards (OPSS) have reviewed the requirement to label the product with the UK Responsible Person and have decided to extend this transitional provision for a total period of five years, until 31 December 2025.

Read More »