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UK Packaging EPR & Plastic Packaging Tax: Key Regulatory Updates – April 2025

Updated: May 19


April 2025 brought significant regulatory developments that will shape the future of packaging compliance in the UK. Two major announcements—one from Department of Environment, Food and Rural Affairs (DEFRA) under the Packaging Extended Producer Responsibility (pEPR) framework, and another from HM Revenue and Custom (HMRC) on the Plastic Packaging Tax (PPT)—are poised to affect producers, recyclers, and stakeholders across the packaging value chain.


  1. DEFRA Releases RAM Version 1.1 – Simplifying Compliance for Producers:


    In a much-anticipated move, DEFRA released Version 1.1 of the Recyclability Assessment Methodology (RAM)—an update to its December 2024 edition. 


    This new version introduces critical simplifications to the assessment criteria, particularly reducing “Red” and “Amber” category requirements that were complex and restrictive for producers. 


Key Simplifications in RAM v1.1:


Comparison of Recyclability Assessment Methodology (RAM) v1.0 and v1.1
Comparison of Recyclability Assessment Methodology (RAM) v1.0 and v1.1

What It Means: 


These simplifications reduce data input requirements by approximately 10–15% per packaging type, making it easier for producers to gather RAM-related information. However, compliance still involves detailed evaluations across application, sortation, and reprocessing stages—which directly impact eco-modulated fee structures.


To support producers in navigating this complex data journey, A A Garg & Co. (A2G) has launched ‘pEPR Manage’, a tailored solution for UK packaging compliance.


pEPR Manage: Our comprehensive solution for navigating UK Packaging EPR
pEPR Manage: Our comprehensive solution for navigating UK Packaging EPR

 2. Plastic Packaging Tax (PPT): HMRC’s Strategic Reforms (Effective April 2027) 


HMRC has released two pivotal updates to the UK’s Plastic Packaging Tax (PPT) regime, which will take effect from April 2027


A. Approval of the Mass Balance Approach


Producers can now use chemically recycled plastic in packaging and claim exemption under PPT if the recycled content meets the 30% threshold via a mass balance allocation system.

 

Packaging with ≥30% chemically recycled content (mass balance basis) will be exempt from the £217/tonne tax. 


B. Exclusion of Pre-Consumer Recycled Content 


Only post-consumer recycled (PCR) material will now count toward the 30% threshold. Pre-consumer (PIR) or industrial recycled content is no longer eligible—tightening the focus on end-of-life circularity

 

Key Implications for Businesses 


These changes signal a maturing regulatory environment that both incentivizes innovation and demands accountability: 

  • Reduced reporting complexity through RAM simplifications 

  • Tax relief opportunities through chemically recycled content 

  • Increased demand for traceable, high-quality PCR material 

  • A stronger push for data-driven packaging traceability and reporting 

 

What You Should Do Next 


As compliance becomes more closely tied to recyclability, material traceability, and lifecycle impact, businesses must be proactive in: 


Key actions for obligated entities to adapt to evolving UK EPR and PPT requirements
Key actions for obligated entities to adapt to evolving UK EPR and PPT requirements

If you're a producer navigating the evolving UK EPR landscape, now is the time to act—not just to stay compliant, but to lead sustainably.


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