EPR Guide - Flipbook - Page 24
Future Developments: Labelling,
Deposit Return, etc.
A few other upcoming aspects of the UK packaging EPR landscape to keep in mind:
• Recycling Labelling: The UK had planned to mandate a uniform
recycling label (“Recycle” or “Do not recycle” iconography on all
consumer packaging) by 2027. This requirement was removed
from the 2024 regulations at the last minute to avoid delaying
EPR, but it remains a likely future measure. It’s widely expected
that once details are ironed out, mandatory on-pack recycling
labels will be introduced (possibly by 2027/28).
Companies should anticipate this and consider aligning their packaging artwork with the
anticipated labelling scheme, as it will dovetail with EPR’s recyclability focus.
• Deposit Return Scheme (DRS): The UK is pursuing a DRS for drink containers (plastic bottles,
cans, etc.) separate from EPR. The current EPR law has a contingency: if the DRS for England
(and matching schemes in other nations) is not up and running by 2028, then drink containers
will fall back into scope of EPR fees from 2028 onward. In other words, producers of drinks in
PET, aluminium, steel, glass might have to pay into EPR if DRS is delayed. As of 2026, DRS plans
are moving forward (Scotland’s was delayed, England’s slated for 2025–26), but companies in
beverages should watch this space closely.
• Possible Inclusion of More Producers: Right now, small producers don’t pay fees the
obligation falls on their supplier, business waste is handled via commercial channels. However,
the scheme could broaden. For example, if free-riding by small 昀椀rms becomes signi昀椀cant,
government might decide to introduce some fee for smaller producers (even if minimal) in later
years. Also, strategies to handle non-household packaging waste might come, possibly through
other policies. Keep an eye on consultations or reviews post-2028 that might adjust the scope.
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