LEGISLATION
UK Packaging Waste Regulations Explained
UK packaging waste law changed fundamentally from 1 January 2025. The previous producer responsibility system – which ran for nearly 18 years – has been replaced by a new Extended Producer Responsibility (EPR) regime. If your business handles, supplies, or imports packaging, understanding the current legislative landscape, how PRNs and PERNs work, and what essential design requirements apply is essential for maintaining compliance.
The Legislative Framework
Three pieces of legislation govern packaging waste in the UK:
Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332)
The operative EPR framework since 1 January 2025. Requires packaging producers meeting the relevant thresholds to register, report packaging data, obtain PRNs or PERNs, and contribute to the costs of collecting and recycling household packaging waste. Applies UK-wide. Full details are in our guide to extended producer responsibility for packaging.
Packaging (Essential Requirements) Regulations 2015 (SI 2015/1640)
Still in force. Sets design and composition standards for all packaging placed on the UK market – regardless of producer obligation thresholds. Applies to manufacturers and importers of any size.
Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (SI 2007/871) – Revoked
Warning
The previous framework. In force from 2007 until 31 December 2025, then formally revoked on 1 January 2026 by SI 2024/1332. GOV.UK guidance for the 2007 Regulations was withdrawn on 7 January 2025. If your compliance procedures still reference the 2007 framework, they need updating.
The Transition: From the 2007 Regime to EPR
For nearly 18 years, UK packaging producer responsibility operated under the 2007 Regulations. Under that system:
- Businesses with turnover above £2 million AND handling 50 tonnes or more of packaging per year were obligated
- Obligations were discharged primarily by purchasing PRNs or PERNs from accredited reprocessors and exporters
- Most producers joined a compliance scheme – such as Valpak, Ecosurety, or DS Smith Recycling – which managed obligations collectively on their behalf
- An annual Certificate of Compliance was submitted to the Environment Agency by 31 January each year
The 2024 EPR Regulations (SI 2024/1332) came into force on 21 December 2024, but the 2007 Regulations remained the operative compliance framework through 31 December 2025 – formally revoked on 1 January 2026. During 2025, producers had obligations under both regimes simultaneously: continuing to meet 2007 compliance requirements while collecting data for the new EPR reporting system. The fundamental obligation – funding packaging recovery and recycling – remains, but the mechanism changed significantly:
- The thresholds shifted: large producers (turnover £2 million+ AND 50+ tonnes) and a new small producer tier (turnover £1 million+ AND 25+ tonnes)
- A new waste disposal fee mechanism funds local authorities’ household packaging collection costs, applying to large producers from October 2025
- PRNs and PERNs continue to operate alongside the new fee system, but only for large producers – small producers have data reporting obligations only
Key point
If your business was not previously obligated under the 2007 Regulations, check whether the new thresholds bring you into scope. The small producer tier is new – businesses with turnover above £1 million handling more than 25 tonnes of packaging may now have obligations they did not have before. Full guidance on thresholds and what to do is available at GOV.UK.
The PRN and PERN System
Packaging Recovery Notes (PRNs) and Packaging Export Recovery Notes (PERNs) are the compliance currency of UK packaging waste law. They applied under the 2007 Regulations and continue to apply under the 2024 EPR regime.
What PRNs and PERNs Are
A PRN (Packaging Recovery Note) is issued by an accredited UK reprocessor to certify that one tonne of a specific packaging material has been recycled within the UK. A PERN (Packaging Export Recovery Note) is the equivalent for packaging material exported for recycling overseas. Both types are tracked electronically on the National Packaging Waste Database (NPWD).
How the System Works
- Only accredited reprocessors and exporters – registered with the Environment Agency, SEPA, NRW, or NIEA – can issue PRNs and PERNs. Accreditation is applied for via GOV.UK
- Large producers only (or their compliance schemes) purchase PRNs or PERNs on the open market to evidence that sufficient material has been recycled on their behalf. Small producers have data reporting obligations only and do not need to acquire PRNs or PERNs
- Notes are issued by material type – covering paper, glass, steel, aluminium, plastic, wood, and composite packaging
- PRN and PERN prices are not fixed: they fluctuate based on market supply from reprocessors and demand from obligated producers
PRNs Under the 2024 EPR Regulations
PRNs and PERNs continue to operate under the 2024 Regulations but sit alongside the new waste disposal fee system. They serve different purposes:
- PRNs/PERNs – evidence that packaging material has been recycled or recovered (the producer’s recycling obligation)
- Waste disposal fees – fund local authorities’ costs of collecting and sorting household packaging waste
Producers must satisfy both obligations. Compliance schemes calculate and manage the combined obligation on behalf of their members. Full details of how recycling obligations and disposal fees interact are covered in our EPR for packaging guide.
Packaging (Essential Requirements) Regulations 2015
While producer responsibility law focuses on who funds recycling, the Packaging (Essential Requirements) Regulations 2015 (SI 2015/1640) set legal standards for how packaging must be designed and manufactured – regardless of business size or EPR threshold status.
Who They Apply To
These regulations apply to any responsible person – a business that manufactures packaging in the UK, imports packaging for placing on the UK market, or is otherwise responsible for making packaging available to customers in Great Britain or Northern Ireland. The essential requirements apply to sales packaging, secondary (grouped) packaging, and transport (tertiary) packaging.
The Essential Requirements (Schedule 1)
1. Packaging minimisation
Packaging must be designed and manufactured so that its volume and weight are limited to the minimum adequate amount to maintain the necessary level of safety, hygiene, and acceptability for the packed product and consumer.
2. Design for reuse and recovery
Packaging must be designed, produced, and commercialised in such a way as to permit its reuse or recovery – including recycling – in line with the waste hierarchy. Its impact on the environment when it becomes waste must be minimised.
3. Hazardous substance minimisation and heavy metal limits
Packaging must be manufactured so that the presence of noxious and other hazardous substances and materials is minimised with regard to their presence in emissions, ash, or leachate when packaging or residues from its management operations are incinerated or landfilled.
Separately, Regulation 5 of the 2015 Regulations sets a specific legal limit: the total concentration of lead, cadmium, mercury, and hexavalent chromium in packaging or any packaging component must not exceed 100 parts per million (ppm) by weight. Exemptions apply for lead crystal glass, certain plastic crates and pallets in verified closed-loop systems, and some glass packaging categories.
4. Reusable packaging requirements
Where packaging is designed to be reused, it must be physically capable of a number of trips or rotations under normal conditions of use; it must be processable in a way that meets health and safety requirements for those handling it; and it must meet the recovery requirements applicable to non-reusable packaging at the end of its useful life.
5. Recyclability
Packaging must be manufactured to enable the recycling of a certain percentage by weight of the materials used in its manufacture, in compliance with current recognised harmonised standards.
Demonstrating Compliance
Compliance with the essential requirements is demonstrated by meeting the relevant harmonised CEN standards for packaging and packaging waste. Manufacturers must maintain technical documentation demonstrating compliance. The responsible person must not place packaging on the UK market unless it complies.
Enforcement: The 2015 Regulations are enforced by local weights and measures authorities (Trading Standards) – not by the Environment Agency or other environmental regulators. This is an important distinction from the EPR producer responsibility regime. Criminal penalties apply for non-compliance, with a due diligence defence available.
How the Packaging Regulations Relate to Each Other
| Regulation | Who it applies to | Primary obligation |
|---|---|---|
| EPR Regulations 2024 (SI 2024/1332) | Producers above threshold (brand owners, importers, packer/fillers, sellers) | Register, report packaging data, pay disposal fees, obtain PRNs/PERNs |
| Essential Requirements Regulations 2015 (SI 2015/1640) | Any business manufacturing or importing packaging for the UK market | Design packaging to meet minimisation, recoverability, and hazardous substance standards |
| Plastic Packaging Tax (Finance Act 2021) | Manufacturers and importers of plastic packaging (10-tonne annual threshold) | Pay tax at the current HMRC rate per tonne unless packaging contains at least 30% recycled content – see our Plastic Packaging Tax guide for current rates |
This guide reflects UK packaging waste legislation as in force at March 2026. The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (SI 2007/871) were formally revoked on 1 January 2026. The operative producer responsibility framework is now the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332), which came into force on 21 December 2024. The Packaging (Essential Requirements) Regulations 2015 (SI 2015/1640) remain separately in force.