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.
Fee modulation based on packaging use
From 2026 onwards, producers will also see increasing emphasis on fee modulation. Packaging will be assessed based on necessity, efficiency, and levels of excess, with these criteria influencing the final fee a producer pays.
Packaging considered unnecessary, oversized, or difficult to recycle may incur higher costs, while optimised, minimal, or highly recyclable packaging can attract reduced fees. This shift encourages businesses to evaluate their packaging portfolios more closely and make smarter, sustainability-led decisions to avoid avoidable cost increases.
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.
