Guidance

Extended Producer Responsibility for Packaging (pEPR) recyclability assessment obligations: RPS 350

Published 27 June 2025

Applies to England

© Crown copyright 2025

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This publication is available at https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-pepr-recyclability-assessment-obligations-rps-350/extended-producer-responsibility-for-packaging-pepr-recyclability-assessment-obligations-rps-350

This regulatory position (RPS) does not change your legal requirement to assess, collect and report data relating to recyclability of household packaging supplied in the period 1 January to 30 June 2025.

However, the Environment Agency will not normally take enforcement action against you if you do not comply with these legal requirements provided that:

  • your activity meets the description set out in this RPS

  • you comply with the conditions set out in this RPS

1. Activity this RPS applies to

This RPS applies to producer obligations to assess, collect and report data relating to recyclability of household packaging supplied in the period 1 January to 30 June 2025.

The reporting obligations described in this RPS might change depending on whether the producer is a member of a compliance scheme or group registration (or both). 

This RPS does not apply to any other obligations under the 2024 regulations.

2. Conditions you must comply with

You must comply with either:

  • your recyclability assessment obligations under the 2024 regulations for the reporting period 1 July to 31 December 2025, on or before 1 April 2026

  • your recyclability assessment obligations under the 2024 regulations for the reporting period 1 January to 30 June 2025 and for the reporting period 1 July to 31 December 2025 on or before 1 April 2026

Before using this RPS you must read the statement made by PackUK to understand how using this RPS will affect your disposal fee liability for the assessment year 1 April 2026 to 31 March 2027.

3. Things to note

This RPS gives producers more time to comply with the scheme administrator, PackUK’s Recyclability Assessment Methodology for household packaging supplied in 2025. Affected producers have additional time to either:

  • comply with their recyclability assessment obligations for the reporting period 1 January to 30 June 2025

  • rely on the assessment made in the next reporting period

The obligations referred to in this RPS are the requirements for liable producers to:

  • assess the recyclability of household packaging in accordance with regulations 25(3)(a) and 26 in relation to household packaging supplied in the reporting period 1 January to 30 June 2025

  • keep records of the recyclability assessments in accordance with regulations 25(3)(b) and 34(5) of the 2024 regulations

  • report the recyclability assessments to the Environment Agency in accordance with regulations 25(3)(c), 37 and 39 of the 2024 regulations, on or before 1 October 2025

4. When you must check back

The Environment Agency will withdraw this RPS on 31 January 2027.

The Environment Agency can withdraw or amend this regulatory position if they consider it necessary. This includes where the activity that this RPS relates to has not changed. 

You will need to check back from time to time to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn. 

You can subscribe to email updates about this RPS. These will tell you if the RPS has changed and when it has been withdrawn.

5. Contact the Environment Agency

If you have any questions about this RPS email enquiries@environment-agency.gov.uk and put RPS 350 in the subject.

6. Contact PackUK

If you have any questions about the impact that reliance on using this RPS may have on your disposal fee liability for the assessment year 1 April 2026 to 31 March 2027, please contact PackUK by emailing EPRCustomerService@defra.gov.uk.

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