UK packaging regulations 2026: three charges in all four nations, and drinks deposits from 1 October 2027

UK packaging regulations, nation by nation

The four nations share the tax and the EPR regime but legislate apart on deposits, plastic bans and household collection (Exhibit 2). SPI counts the instruments in force or with a fixed start date in each nation; the count is a reading aid, not a measure of burden. Each rule has its own page on the SPI Regulation Tracker for the United Kingdom.

England. England carries the most instruments in SPI’s count because Simpler Recycling sits on top of the shared rules. Since 31 March 2026 English councils must collect paper and card, other dry recyclables, food and garden waste from every household, flats included, and plastic film and bags join plastic collections by 31 March 2027 (Defra Simpler Recycling guidance). The single-use plastic ban in SI 2023/982 has applied since 1 October 2023 and exempts plates, trays and bowls that are packaging.

Scotland. Scotland’s deposit scheme started life in 2020 with glass and a 1 July 2022 date. SSI 2025/188, made on 19 June 2025, took glass out, raised the size floor to 150 ml and moved the start to 1 October 2027, and SSI 2025/189 named UK Deposit Management Organisation Limited, trading as Exchange for Change, as the administrator. On 26 October 2026 the Scottish Government published an addendum assessing further 2026 amendments, including a choice for hospitality venues not to charge a deposit on drinks consumed on site and the end of export shop exemptions. SPI has not yet confirmed whether those 2026 amendments have been made. Scotland’s single-use plastic ban, SSI 2021/410, has applied since 1 June 2022.

Wales. Wales is the outlier on glass. WSI 2026/103, made by the Welsh Ministers on 25 March 2026, brings aluminium, glass, PET and steel containers of 150 ml to 3 litres into a deposit scheme from 1 October 2027, but sets the deposit on a glass item at 0 pence from 1 October 2027 to 30 September 2031, with Natural Resources Wales as enforcer. The Welsh Act of 2023 bans a wider list of single-use plastics than England, and adds plastic wet wipes from 18 December 2026 (WSI 2025/716).

Northern Ireland. Northern Ireland shares England’s deposit instrument, SI 2025/67, made with DAERA’s consent, and DAERA enforces it there. It is the only nation where the EU’s PPWR applies, in part, and DAERA’s own page says the rules reach businesses placing packaging on the Northern Ireland or EU market, not packaging placed on the market in England, Scotland or Wales. Its single-use plastic bans under Directive (EU) 2019/904 are still being transposed, with legislation expected in 2027 (DAERA, updated 14 April 2026).

Plastic Packaging Tax obligations in 2026 and 2027

Plastic Packaging Tax (PR-GB-001) is a UK-wide HMRC tax set in Part 2 of the Finance Act 2021. It charges each finished plastic packaging component made in or imported into the UK, empty or filled, when recycled plastic is less than 30% of its plastic. It is a cliff, not a slope: at 30% the component pays nothing, below it the whole weight pays. A business must register when it has made or imported 10 tonnes of finished components in the last 12 months, or expects to in the next 30 days (HMRC, updated 12 February 2026).

Three changes are dated. On 1 April 2027 the rate rises 3.4% to GBP 236.56, by SPI’s calculation from the Budget 2026 rates annex. On the same day pre-consumer scrap stops counting as recycled plastic, and chemically recycled plastic can count only when it is attributed through a certified mass balance scheme (HMRC policy paper, 26 November 2025). And from 1 April 2030 HMRC intends to make certification mandatory for mechanically recycled plastic, for businesses that claim the 30% exemption (HMRC consultation outcome, 28 October 2026). The draft certification regulations for chemical recycling, and how they compare with the EU’s bottle rules, are covered in SPI’s piece on mass balance and chemically recycled plastic; the 2030 decision is in SPI News on HMRC’s certification outcome.

HMRC reports GBP 250 million of receipts for 2025 to 2026, down from GBP 261 million, and 5,142 registered businesses at 13 August 2026. Declared tonnage fell from 3,138 thousand to 2,970 thousand tonnes in the same period (HMRC statistics, updated 27 August 2026).

UK EPR regulations 2026: who reports, who pays and when

Packaging EPR (PR-GB-002) rests on SI 2024/1332, made on 11 December 2024 and in force across all four nations, with the Environment Agency, Natural Resources Wales, SEPA and DAERA as the appropriate agency in each (regulation 5). Regulation 24 sets two tiers. A small producer has turnover above GBP 1,000,000 and handles more than 25 tonnes of packaging a year; a large producer passes GBP 2,000,000 and 50 tonnes. Both tests must be met.

Packaging reporting runs on fixed dates. Large producers report every six months: 1 January to 30 June 2026 data was due by 1 October 2026, and 1 July to 31 December 2026 data is due by 1 April 2027. Small producers report once, with full-year 2026 data due by 1 April 2027. Large producers register each year and pay their fees by 1 October; small producers register and pay a registration fee by 1 April (GOV.UK reporting deadlines, updated 19 August 2026).

Only large producers that supplied household packaging pay disposal fees (PR-GB-003). The GOV.UK guidance updated on 28 October 2026 says notices of liability go out at the end of each calendar year and payment is usually in instalments. PackUK’s operational plan puts the year 2 calculation in November 2026, with a single notice of liability by the end of that month and no plan for a producer-wide recalculation, on data frozen on 1 September 2026.

The modulation path is set. Red-rated packaging pays 1.2 times amber in 2026 to 2027, 1.6 times in 2027 to 2028 and 2.0 times in 2028 to 2029, and the extra money funds a discount on green, so total fees do not rise (PackUK modulation statement). How a red, amber or green rating changes one bill, and how the green discount is worked out, is the subject of SPI’s UK EPR year 2 RAM ratings piece; this hub does not repeat it.

Two items sit outside the disposal fee. Registration charges paid to the agencies and the cost of meeting recycling obligations with evidence notes are billed apart. And from year 2, single-use PET, aluminium and steel drinks containers of 150 ml to 3 litres leave the EPR household tonnage, because the deposit schemes take them (SPI fee-market notes for the United Kingdom, from PackUK’s year 2 document).

Penalties are civil first. A fixed monetary penalty under Schedule 13 is GBP 1,000, and a producer that leaves disposal fees unpaid 50 days after the due date risks a variable penalty of 20% of the unpaid fees or 5% of reported turnover, whichever is higher. Offences under regulation 115, such as trading without registration, can lead to an unlimited fine in England and Wales.

Deposit return in 2027: one start date, three laws

All four nations start drinks deposits on 1 October 2027, but the texts differ in scope and enforcement (Exhibit 6). Exchange for Change runs the scheme in England, Northern Ireland and Scotland, and its FAQ describes a coordinated approach that includes Wales; SPI has not yet confirmed the Welsh appointment instrument.

A scheme producer is the UK-established manufacturer, brand owner, importer or filler to order. It registers with the operator, labels each item with the scheme logo and return code, and pays the operator an amount equal to the deposit for every item it supplies (SI 2025/67, regulation 22). Exchange for Change says it is exploring a transition period with regulators for non-scheme stock still in the supply chain at launch; SPI has not yet confirmed how drinks filled before 1 October 2027 will be treated. Product lines under 6,250 units in the first 15 months of the scheme, to December 2028, and 5,000 a year after, according to the operator’s FAQ, can be registered as low volume lines, outside the deposit and labelling duties.

Producer fees start at zero. Exchange for Change’s September 2026 newsletter sets the fee at 0p for the first 15 months, to December 2028, and expects 2.3p per PET container and 0.6p per aluminium or steel container from January 2029 to December 2032, to be reviewed and reconfirmed in May 2027. Phase 1 registration opened on 29 September 2026 and phase 2 opens in January 2027. The first certified return machines and Scotland’s 2026 amendments are covered in SPI News on the UK deposit return scheme for 2027.

Single-use plastic bans and the Northern Ireland overlay

The single-use plastic bans touch packaging mainly through food service. England’s SI 2023/982 (PR-GB-006) bans single-use plastic plates, trays and bowls, cutlery, balloon sticks and polystyrene food and drink containers and cups supplied to end users, but exempts plates, trays and bowls that are packaging, such as a pre-filled salad bowl. The fixed penalty is GBP 200. Wales’s Act (PR-GB-007) bans a similar list for supply to consumers, and its bans on polystyrene lids, thin carrier bags and oxo-degradable plastic are written into the Schedule but not yet commenced. Scotland’s SSI 2021/410 bans expanded polystyrene cups, food and drink containers and plates and several plastic items from 1 June 2022, with a fine on summary conviction of up to level 5.

Northern Ireland is the exception twice over. It has no single-use plastic item ban yet, and DAERA lists the transposition of Articles 2 to 7 of the Directive as in progress, expected in 2027. But since 12 August 2026 it has applied much of the EU PPWR, so packaging placed on its market must meet EU requirements in force from that date, including rules on substances in packaging. A UK brand shipping one pack to Belfast and Glasgow may need two compliance files.

Thresholds and penalties for exporters to the UK

The thresholds differ by rule and unit (Exhibit 7). They are in each law’s own terms and are not comparable across rules.

For a foreign supplier, the question is not usually whether it is a producer but which UK business is, and what that business will ask for. The SPI piece on UK groups under EPR and Plastic Packaging Tax shows how large UK retailers and brand owners report these costs.

A framework: five exporter archetypes

SPI groups businesses that send packaging or packed goods into the UK into five archetypes, by how the goods enter (Exhibit 8). Each column names the business the text points to, before any size test.

Archetype A, packed goods through an importer. This is the most common route, and both money flows land on the UK importer. Under section 44 of the Finance Act 2021 the tax is due on chargeable components imported on a business’s behalf, whether the packaging is empty or holds goods, and the importer counts those tonnes toward its own 10 tonne test.

Archetype B, marketplace sellers. Regulation 20 of SI 2024/1332 lets the marketplace operator be the producer for packaging an overseas seller ships to UK buyers. The tax position of small direct parcels is less clear, and SPI has not yet confirmed how HMRC treats them.

Archetype C, packaging suppliers. An overseas converter selling empty trays or film into the UK never pays EPR, but its customer’s tax bill depends on the recycled share it can document, because section 49 presumes plastic is not recycled unless shown otherwise.

Archetype D, drinks brands. The overseas brand needs a UK-established producer for each line, with labels changed for 1 October 2027; how stock filled before then is treated is not yet confirmed.

Archetype E, Northern Ireland. Goods placed on the Northern Ireland market meet UK and EU rules at once.

Scenarios: what one tonne of imported plastic packaging costs

SPI priced one tonne of household plastic packaging imported filled by a UK large producer, in GBP only (Exhibit 9). Each case changes the recyclability rating, the recycled share or the year.

SPI calculation: in the base case the tax is 33.5% of the GBP 683.82 per tonne. Moving from the high case to the low case saves GBP 358.82 a tonne, of which GBP 228.82 comes from reaching 30% recycled plastic and GBP 130.00 from moving from red to green. In 2026 to 2027 the recycled content lever is worth more than the rating; in the stress case the red to green gap alone would be GBP 313.00 if green stayed at GBP 415, which shows why the rating gains weight as the red factor climbs.

The same tonne carries no deposit cost unless it is a drinks container in scope, and then it leaves the EPR tonnage. Exhibit 10 prices that case per container.

Where SPI goes deeper on each UK rule

This page is a map. Each rule in Exhibit 1 has a fuller SPI treatment, and this section says what each one adds so that readers can go straight to the right piece.

EPR fees and RAM ratings. The UK EPR year 2 RAM ratings piece works through how PackUK’s red, amber and green ratings turn into a bill, how the green discount is funded by the red uplift, and how the gap between a red and a green tonne widens as the red factor climbs from 1.2 to 2.0 by 2028 to 2029. Read it before the year 2 notice of liability arrives at the end of November 2026, because the confirmed fees will be applied to the same ratings.

How large UK groups carry the cost. The UK groups piece reads what Tesco, Reckitt, GSK, Haleon and ALDI UK report about EPR and Plastic Packaging Tax in their own filings. It is the place to see how retailers and brand owners describe the two charges to investors, and which of them weighs more for each business model.

Recycled content evidence. The mass balance piece compares HMRC’s draft chemical recycling certification rules of 6 October 2026 with the EU’s method for single-use bottles. It matters to any supplier that plans to claim chemically recycled content toward the 30% line from 1 April 2027.

News that moves the dates. SPI News follows the two fastest-moving files. The piece on HMRC’s certification outcome covers the 28 October 2026 decision to require certified mechanically recycled plastic from April 2030 and the Budget rate of GBP 236.56. The piece on the UK deposit return scheme for 2027 covers the first certified return machines and Scotland’s October 2026 cost addendum.

Rule pages. The SPI Regulation Tracker for the United Kingdom holds the rule pages for PR-GB-001 to PR-GB-007, each with scope tests, obligations by role, enforcement and a dated history. The Welsh deposit regulations, Scotland’s single-use plastic ban and the Northern Ireland PPWR overlay are not yet tracker rules, so for now they appear on this page only.