UK packaging recycling obligations 2026 fall due on 31 January 2027, with plastic cut to 83% in England

How UK packaging recycling obligations work

The recycling obligation is the older half of UK packaging producer responsibility. Under the Packaging Regulations 2024 (SI 2024/1332, tracked by SPI as PR-GB-002), a large producer must recycle, through evidence, a set share of the packaging it supplied in each material, and must furnish a certificate of compliance¹³. Disposal fees paid to PackUK for household packaging are a separate bill.

The evidence takes the form of packaging waste recycling notes (PRNs), issued by accredited UK reprocessors, and packaging waste export recycling notes (PERNs), issued by accredited exporters. Each note stands for one tonne of packaging waste recycled. The GOV.UK guidance says producers can buy directly from accredited reprocessors and exporters on the public register, use a trading platform or broker, issue their own if accredited, or join a compliance scheme that buys for them¹.

Notes are material-specific. A plastic PRN cannot count towards a glass obligation, and each material’s status in the Report Packaging Data (RPD) service must show “Met” before the producer is done. Obligations appear in RPD once full-year data is reported and accepted by the regulator, and they are issued during the calendar year with the deadline falling the following January.

The deadline is written in plain terms.

The guidance gives the worked case: a producer that reported packaging data for calendar year 2025 must meet those obligations, certificate included, by 31 January 2027. Small producers, by turnover and tonnage under regulation 24, have no recycling obligation and pay no disposal fees.

Group structures can move the figure during the year. Where subsidiaries join or leave a group mid-year, the guidance says obligations may shift between registrations, and it points producers to appendix 9 of the agreed positions guidance on the National Packaging Waste Database¹.

For the wider map of UK packaging law, including the rules this piece does not cover, SPI’s Ledger guide to UK packaging regulations is the starting point.

What changed in the last four weeks

23 September: a scheme warns on plastic. ERP UK, a compliance scheme in the Landbell Group, published an assessment of a PRN market under strain, citing rising prices, slower evidence flows, accreditation delays and new export reporting rules. It named plastic as the material under most pressure and said steel was behind its expected compliance path, while wood prices had risen⁹.

9 October: the Environment Agency issues RPS 383. The regulatory position statement covers large producers and compliance schemes in England for the 2026 compliance year. The Environment Agency said it would not normally take enforcement action where they meet at least 83% of the plastic obligation, 92% of steel and 90% of wood; every other material stays at 100%².

The statement attaches conditions. Producers must keep records showing compliance with it for five years from the date they last relied on it, provide them on request, and tell the Environment Agency immediately, by email, if they cannot comply. It does not change the legal duties to register, report data or meet the obligation, and its end date is fixed.

RPS 383 also says the certificate of compliance, issued at the end of the compliance year, will record non-compliance with the statutory obligation even where a producer meets the RPS conditions.

9 October: Defra explains the cause. As letsrecycle.com reported, Defra linked the shortage of notes to 2026 changes aimed at PRN integrity, fraud and transparency, which cut the number of accredited reprocessors and exporters. It also cited the late start of the new evidence system, which went live in mid-February, leaving no notes issued for about six weeks, and a rule that exporters must wait until material is received before releasing PERNs¹⁰.

The same report said the Scottish, Welsh and Northern Irish statements were due shortly, that regulators would add a public register category for businesses meeting the adjusted levels, and that compliance schemes meeting them would not be disadvantaged in their 2027 approval assessments.

28 October: GOV.UK rewrites the producer guidance. The change note on the large producer guidance says the update clarified how to acquire PRNs and PERNs, added examples on December waste, explained the 31 January deadline and the new certificate process, added yearly glass re-melt targets, and moved disposal fee content to a separate guide¹. PackUK’s disposal fee guide, renamed the same day from “EPR for packaging: Notice of liability”, now explains how fees are calculated and how illustrative fees differ from confirmed ones³.

29 October: the collection page catches up. The GOV.UK collection for EPR for packaging added the new disposal fee guide under large producers on 29 October, after adding a page on issuing PRNs and PERNs on 8 October⁴. Neither the collection nor the producer guidance links to RPS 383, which sits with the Environment Agency’s position statements.

UK packaging recycling obligations 2026, material by material

The table below sets out what the GOV.UK guidance and RPS 383 require, line by line, and what each line means for a large producer that has not yet closed its 2026 position.

The certificate route. The guidance tells producers to open “Manage your recycling obligations” in RPD, review the certificate once satisfied that it reflects their compliance status, and submit it to their environmental regulator. Only an approved or delegated person can submit it, and members of a compliance scheme leave the filing to the scheme, which submits a statement of compliance covering them¹.

December waste. Notes issued for packaging waste received at reprocessing sites in December carry a blue tag in RPD. The guidance lets a producer apply them all to the current year, all to the following year, or split them, and gives an example of a producer holding 32 tonnes of steel PRNs that accepts a 3 tonne December waste steel PERN and carries it to next year. A February 2026 change already allowed 2025 December waste notes to count towards 2026 obligations.

Glass. The 2026 glass obligation is 76% of 2025 glass tonnage, and 76% of that obligation must be met with re-melt notes, the evidence from glass remade into new glass. The guidance states the 76% re-melt share as a minimum for 2026, and lets the remaining 24% come from re-melt or glass other notes in any mix. RPS 383 leaves both glass figures untouched.

SPI calculation (per 1,000 tonnes of 2025 packaging): a producer that reported 1,000 tonnes of each material for 2025 needs 770 tonnes of paper and board evidence, 760 of glass (577.6 of it re-melt), 620 of aluminium, 810 of steel, 570 of plastic and 460 of wood under the statutory targets. Under RPS 383 in England, steel falls to 745.2 tonnes, plastic to 473.1 and wood to 414.0.

Who is most exposed before 31 January

Plastic-heavy brand owners and retailers. These producers gain most from the English relief and face the tightest evidence market. Supermarkets, own-label food makers and household goods brands carry large plastic tonnages; by SPI’s calculation, each 1,000 tonnes of plastic reported for 2025 needs 570 tonnes of evidence at the statutory rate and 473.1 under RPS 383.

A scale illustration. The SPI Buyers Database holds ALDI UK’s published plastic packaging footprint of 124,940.15 tonnes for calendar year 2023, covering own-label and branded plastic. Applied to the 2026 rates, a tonnage of that size would carry about 71,216 tonnes of plastic evidence at 57% and about 59,109 tonnes at the English 83% level, by SPI’s calculation¹⁴. This is an illustration of scale only, not ALDI UK’s obligation, which rests on the 2025 data it reported as producer.

Drinks and glass-heavy producers. Brewers, distillers, wine importers and soft drinks fillers get no relief: the glass obligation stays at 76% of 2025 tonnage, and 76% of that must be re-melt evidence. ERP UK described glass as comparatively stable, so the constraint is the re-melt share rather than overall supply.

Steel and wood users. Canned food and aerosol producers with steel packaging, and shippers that report wooden pallets and crates, see cuts of 8% and 10% of their obligations in England. Per 1,000 tonnes, steel evidence falls by 64.8 tonnes and wood by 46.0, by SPI’s calculation.

Paper, board and aluminium users. Carton, corrugated and can users get no relief: obligations stay at 77% and 62% of 2025 tonnage. ERP UK described aluminium as comparatively stable, and SPI has not yet confirmed any regulator or scheme statement flagging a 2026 shortfall in paper and board evidence.

Compliance scheme members. Schemes buy against members’ combined obligations and file one statement of compliance. Argus reported Ecosurety’s view that sell-back of surplus PRNs would likely come only from direct buyers, because scheme obligations are pooled¹².

Producers registered in Scotland, Wales and Northern Ireland. RPS 383 applies to England only. SPI has not yet confirmed equivalent statements from SEPA, Natural Resources Wales or the Northern Ireland Environment Agency.

The pinch point: relief that the certificate does not show

RPS 383 changes enforcement, not the law. The statutory obligation is still 57% for plastic, 81% for steel and 46% for wood, and the Environment Agency says the certificate of compliance will record non-compliance with it even where a producer meets the RPS conditions². A producer that buys to 83% of its plastic figure will therefore file a certificate that shows a shortfall.

That matters beyond the regulator. Under regulation 115 of SI 2024/1332, failing the recycling obligation or the certificate of compliance is an offence for a large producer, and regulation 119 provides for a fine with no stated maximum on indictment^5,6. Schedule 13 adds civil sanctions, for example a GBP 1,000 fixed monetary penalty for breach of the data record-keeping duty in regulation 25(1)(b)⁷. The RPS is only the regulator’s statement that it will not normally act, and it holds only while its conditions are met.

The guidance itself does not mention the relief. GOV.UK’s 28 October update lists the full statutory targets and refers producers only to their environmental regulator, with no link to RPS 383 and no mention of penalties for missing 31 January¹. Customers, auditors and investors reading a certificate will see the statutory position unless the producer explains the RPS basis.

How the four UK nations compare

The statutory targets apply across the UK, because SI 2024/1332 covers all four nations. Enforcement does not: each nation’s regulator acts as the appropriate agency under regulation 5, which is why the 2026 relief was issued as an English statement¹³.

Defra told letsrecycle.com that the adjusted levels were set with the four regulators and the devolved governments, which suggests the same percentages, but SPI has not yet confirmed that from a SEPA, Natural Resources Wales or DAERA text. A SEPA document titled as a 2026 to 2027 packaging waste regulatory position is listed online, and SPI has not yet confirmed its contents.

Northern Ireland’s regulator did publish a position statement in September 2026, but it deals with nation data and self-managed organisational waste data, delaying those collection duties to 1 January 2028⁸. It sets no recycling levels.