In this guide, we break down the key updates that producers need to know, explain the role of PROs in supporting compliance, and provide practical steps Swiftpak customers can take to prepare. Whether it’s adapting packaging choices, reporting consumer waste, or exploring sustainable alternatives, understanding these changes now will ensure a smooth transition into the EPR regime in 2026.
Key changes producers need to know
The upcoming EPR amendments introduce several important changes that will affect how producers manage packaging, report data, and calculate their compliance costs in 2026.
Producer responsibility organisation appointment
Under the updated EPR framework, all obligated producers will need to appoint a Producer Responsibility Organisation through PackUK. The PRO becomes the central point of coordination for a business’s compliance activities, holding formal authority to act on behalf of producers.
A PRO’s role includes:
- Managing data submissions
- Ensuring fees are calculated correctly
- Coordinating recycling obligations
By acting as the administrative link between producers and the regulator, the PRO helps streamline day-to-day compliance and ensures that producers remain aligned with the evolving requirements of the EPR scheme.
Self-managed consumer waste reporting
One of the most notable developments is the introduction of self-managed consumer waste reporting. This approach recognises and rewards businesses investing in closed-loop collection and recycling streams.
Where a producer can demonstrate that it collects and recycles its own consumer waste, verified recycling tonnages may be used to offset EPR invoices. This creates both an environmental and financial incentive, supporting higher recycling rates while reducing overall compliance costs for producers who invest in circular solutions.
The RAG rating system and fee modulation
From 2026, EPR uses the Recyclability Assessment Methodology (RAM) to determine the fees producers pay. This system uses a red/amber/green (RAG) rating to reward sustainable design and penalise materials that are difficult to recycle.
The 5 stages of RAM assessment:
- Classification: Identifying the predominant material (e.g., plastic, paper, glass).
- Collection: Assessing if the material is widely collected at kerbside by at least 75% of UK local authorities.
- Sortation: Evaluating if current infrastructure can effectively identify and separate the item.
- Reprocessing: Determining if the material can be successfully turned back into high-quality recyclate without excessive contamination.
- Application: Checking if there is a viable end-market where the recycled material can replace virgin resources.
Currently, only large producers are required to collect and report RAM assessment data. Small producers are not required to submit this recyclability information.
Financial impact: The “Bonus & Malus” system
The RAG rating directly dictates a multiplier applied to your base fee:
- Green: Awarded to materials that are widely recyclable and meet all 5 RAM stages (e.g., clear PET bottles, mono-material cardboard). These materials receive a financial discount.
- Amber: Applied to ‘transitional’ packaging with existing collection or reprocessing challenges. This acts as the baseline for fee calculations.
- Red: Assigned to hard-to-recycle packaging with design specifications that make it difficult to recycle at scale. These materials incur a premium surcharge.
Revised definition of fibre-based composite materials
The rules surrounding fibre-based composites have been refined to align with the Recyclability Assessment Methodology (RAM). Under the updated definitions, fibre-based composites containing less than 5% plastic content will now fall under a more consistent reporting category.
For producers, this means clearer guidance on how these materials should be declared, along with changes to recyclability assessments that may influence fee calculations. The new alignment ensures that fibre-based materials are recognised fairly for their recyclability, offering more accurate reporting and potential cost benefits for businesses using compliant composite formats.