PackUK confirms material sub-categories for packaging reporting 2025-2027
On 22 October 2025, PackUK confirmed the material sub-categories that producers will have to gather and report packaging data against for the first years of pEPR.
Year One
For packaging placed on the market in 2024, producers only had to report their packaging using the existing packaging and waste categories:
- Aluminium
- Fibre-based composite (FBC)
- Glass
- Paper/card
- Plastic
- Steel
- Wood
- Other
This was then reflected in producers’ PRN obligations and Year One disposal fees invoiced out to producers on 14 October 2025.
Year Two
Regulation 7(11) of the UK pEPR Regulations states that the scheme administrator may divide these packaging categories down into further sub-categories through the different processes and publish at least 12 months before they apply. Large producers will therefore, according to previous announcements, have to report their 2025 placed on market data using the above categories, but with the inclusion of the below sub-categories for household packaging:
- Plastic – Rigid
- Plastic – Flexible
This is a data gathering and reporting requirement only and will have no effect on PRN obligations or disposal fees invoiced in 2026. However, what this will serve to do, according to PackUK, is “provide a baseline to forecast future fees”.
Year Three
Packaging placed on the market in 2026 will be reported by large producers in the same way as for the previous year, with the only sub-categories for household plastic packaging. For disposal fee invoices sent to producers in 2027, there will now be a separate base fee for rigid and flexible plastics. N.B.: This doesn’t affect PRN obligation which will still be based on the original packaging and waste categories.
The Rationale Behind Separate Fees for Rigid and Flexible Plastics
There may be a few reasons for this separation of costs between the two formats of plastic:
1. These are packaging formats that are collected and recycled through different processes, with vastly different requirements and involved costs.
Assigning different base fees to each of these material sub-categories will give a more accurate reflection of the costs involved in the collection and management of these materials from households by Local Authorities.
2. The infrastructure involved in the recycling of flexible plastics is unable to meet demand, especially with the future collection of flexible plastics from households from 31 March 2027.
2028 will also see the expansion of the UK Emissions Trading Scheme (ETS) to include waste incineration and energy-from-waste (EfW). What we are potentially going to see, if the UK infrastructure for flexible plastics hasn’t caught up with demand, is an increase in flexible plastics being sent to EfW facilities. The resulting costs would be passed to Local Authorities, and ultimately, back to producers via pEPR disposal fees. Again, by assigning separate base fees for rigid and flexible plastics, this will give a more accurate reflection of which plastics are being recycled, and which are being sent to EfW facilities.
With both Simpler Recycling coming into force for flexible plastics in 2027 and the expansion of ETS for the start of 2028, there is still time for systems and infrastructure to develop to meet rising demand.
We are expecting to see:
- illustrative base fees for 2026 invoices (Year 2) in December 2025, and
- illustrative base fees for 2027 invoices (Year 3), with the rigid/flexible plastic split, to be announced around a similar time in December 2026.
This table illustrates the phased introduction of separate reporting categories for rigid and flexible household plastics for 2025 to 2027.
| Disposal fee invoice date | Packaging placed on market | Reporting categories | Disposal fees | PRNs |
| Year 1: October 2025 | 2024 | Base categories only | Base categories | Base categories |
| Year 2: October 2026* | 2025 | Rigid and Flexible household plastic reported separately | Base categories | Base categories |
| Year 3: July 2027** | 2026 | Rigid and Flexible household plastic reported separately | Rigid and Flexible separate base fees | Base categories |
*This was confirmed recently by PackUK
**This is based on our previous expectation for Year 2, but has yet to be confirmed as either July or October 2027
Source: PackUK: specifying material subcategories under regulation 7(11) - GOV.UK
