Packaging Waste Regulations – A quick guide (2025 update)

The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 were created as the original principle that businesses placing packaging on the UK market were to take responsibility for the waste that they were generating.

These regulations stated that if your business was UK-based, had a turnover of more than £2 million and produced, used, or sold packaging products, you needed to register for the Producer Responsibility Obligations and purchase Packaging Recovery Notes (PRNs) to ensure that your business was paying a fair proportion of packaging recovery and recycling costs.

However, in 2023, the Extended Producer Responsibility (EPR) legislation was phased in, essentially replacing the Producer Responsibility Obligations. This new legislation aims to further increase recycling by making packaging producers responsible for household packaging recycling and recovery costs. Extended Producer Responsibility reporting also requires additional detail regarding packaging data.

Even if these new regulations don’t affect you, it is still wise to complete a packaging audit, as reviewing your packaging use can help you reduce the volume you use and your carbon footprint.

In this guide, we’ll provide a full explanation of what these regulations are. Plus, it also shows how to check if it affects your business and the steps to take if it does.

Packaging Waste Recovery Notes (PRNs) are a type of certificate issued by accredited preprocessors and exporters that provides evidence of the recycling of packaging waste.

They were initially formed as part of the Producer Responsibility Obligations regulations in 2007; however, even with the introduction of the Extended Producer Responsibility legislation, PRNs remain essential in the transition phase. While the legislation shifts more of the cost burden onto producers, the PRN system still provides the practical mechanism to evidence recycling performance. This means:

• Businesses under EPR may still need PRNs to demonstrate recycling compliance until EPR is fully embedded.
• PRN prices fluctuate based on supply and demand for recyclable material, so businesses face cost variability.
• Funds raised from PRNs/PERNs continue to support investment in the UK recycling infrastructure and capacity.

In April 2022, HMRC introduced the Plastic Packaging Tax. The tax covers plastic packaging products that do not contain at least 30% recycled content and targets both UK producers and importers of plastic packaging. It also covers packaging that is already  “filled” when imported into the UK.

The tax provides a clear economic incentive for businesses to use recycled plastic material in their packaging, which should create a greater demand for recycled plastic material and stimulate increased levels of recycling and collection of plastic waste.

You can find out more about the Plastic Packaging Tax in our beginners’ guide.

The Packaging (Essential Requirements) Regulations set out rules to ensure that packaging placed on the UK market is designed with waste reduction and sustainability in mind. They require that:

• Packaging must be minimised by volume and weight whilst maintaining safety, hygiene and standards.
• Packaging must be designed so it can be reused, recovered, or recycled where possible.
• Hazardous substances like heavy metals are restricted to prevent environmental harm.

These regulations may be separate from Packaging Waste Regulations, but they do work hand-in-hand with them. While current Packaging Waste Regulations focus on how businesses fund and report the recovery and recycling of packaging waste, the Essential Requirements address the design stage by ensuring that packaging is not excessive and can be managed sustainably at the end of life.

In the current landscape, this link is more important than ever, with Extended Producer Responsibility fees now influenced by recyclability through the Recycling Assessment Methodology. If businesses fail to design their packaging in line with the Essential Requirements, they risk facing higher costs under the Packaging Waste Regulations.

Responsibility depends on whether your business is classed as an “obligated producer”. Under the old Producer Responsibility Obligations, this meant UK businesses with a turnover of more than £2 million and handling more than 50 tonnes of packaging per year.

With the introduction of Extended Producer Responsibility, the scope has widened. Now, businesses may be responsible if they:

• Manufacture, import, or fill packaging that ends up with consumers.
• Supply packaged goods under their own brand.
• Import packaged products into the UK for sale.

Those that are obligated are then split by large producers and small producers, which will affect your fees from there. The responsibility sits with businesses that place packaging on the market, not with consumers or local authorities. Obligated companies must ensure compliance by reporting accurate packaging data, funding waste management through fees, and, in some cases, purchasing PRNs.

In practice, the regulations work by placing the cost of packaging waste management onto businesses rather than taxpayers. Producers are required to:

• Record their packaging data, including the amount and type of packaging they place on the market.
• Contribute to recovery and recycling costs, either through PRNs/PERNs, or EPR fees.
• Design packaging responsibly, meeting requirements set by the Essential Requirements regulations to minimise environmental impact.

If your business meets the criteria, you must register either:

• Directly with the regulator (e.g., the Environment Agency in England), or
• Through a compliance scheme that manages obligations on your behalf.

Registration deadlines and reporting windows are strict, and penalties can apply for late or incomplete compliance. Many businesses find it easier to work with a compliance scheme, which handles PRN purchasing, data submission, and any updates on regulatory changes.

Data requirements have expanded under Extended Producer Responsibility, and businesses must now provide more detailed information on:

• Packaging materials (plastic, glass, aluminium, steel, paper/card, wood).
• Packaging type (household vs. non-household)
• Recyclability of materials
• Imported and exported packaging

This detailed reporting allows regulators to calculate accurate compliance fees based on recyclability and ensures that costs are fairly distributed among producers.