PackUK: specifying material subcategories under regulation 7 (11)
Updated 19 December 2025
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The categories which packaging and waste is to be treated as falling into for the purposes of the Extended producer responsibility (EPR) for packaging scheme are specified in regulation 7(5) of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (‘the Regulations’).
Regulation 7(11) allows PackUK the discretion to specify sub-categories of the packaging and categories listed in regulation 7(5).
PackUK intends to exercise its discretion to specify sub-categories within the existing packaging category of ‘plastic’. This publication confirms the new sub-category list (in accordance with the publication requirements outlined in regulation 7(16)) which will apply to Year 2, Year 3 and Year 4 of the Extended producer responsibility (EPR) for packaging scheme (covering 2026 to 2027, 2027 to 2028, and 2028 to 2029 disposal fees respectively).
The sub-categories will not apply to disposal fees in Year 1 (covering 2025 to 2026).
Year 2: 2026 to 2027 disposal fees
In Year 2, PackUK intends to exercise its discretion to specify two sub-categories within the existing packaging category ‘plastic’ namely the sub-categories: rigid and flexible.
These sub-categories apply solely to large producers and compliance schemes reporting on behalf of large producers.
The sub-categories will also apply solely to packaging supplied in 2025 calendar year. They will be relevant to the obligations in the provisions relating to record keeping (under regulation 34) and the obligations in the provisions relating to data reporting (under regulation 35), to provide a baseline to forecast future fees.
In Year 2 packaging and waste categories are:
- aluminium
- fibre-based composite
- glass
- paper and card
- plastic
- steel
- wood
- other
Packaging and waste sub-categories are:
- plastic – rigid
- plastic – flexible
Application
In Year 2, these new sub-categories will apply solely to large producers and compliance schemes reporting on behalf of large producers.
In this year, the sub-categories will apply to packaging supplied in 2025 calendar year and are relevant to the obligations in the provisions relating to record keeping (under regulation 34) and the obligations in the provisions relating to data reporting (under regulation 35)
The sub-categories will not be relevant to the producer responsibility to pay disposal fees in Year 2 (2026 to 2027), under Part 5, Chapter 3 of the Regulations.
The sub-categories will also not be relevant to the recycling obligations under regulation 40 in Year 2 (2026 to 2027).
The sub-categories apply to reporting for household and commonly binned or littered items of packaging as required to be reported under schedule 4 paragraph 6 (household packaging) and paragraph 10 (commonly binned or littered packaging) of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.
Year 3: 2027 to 2028 disposal fees
In Year 3 PackUK intends to exercise its discretion to specify two sub-categories within the existing packaging category ‘plastic’ namely the sub-categories: rigid and flexible.
These sub-categories will be relevant to the obligations in the provisions relating to data reporting (under regulation 35) and to the obligations in the provisions relating to the producer responsibility to pay disposal fees.
The sub-categories will not apply to producer and recycling obligations (under regulation 40).
In Year 3 packaging and waste categories are:
- aluminium
- fibre-based composite
- glass
- paper and card
- plastic
- steel
- wood
- other
Packaging and waste sub-categories are:
- plastic – rigid
- plastic – flexible
Application
In Year 3, these sub-categories will only apply to large producers and compliance schemes reporting on behalf of large producers.
The sub-categories will apply to packaging supplied in the 2026 calendar year and are relevant to obligations in the provisions relating to record keeping (under regulation 34) and obligations in the provision relating to data reporting (under regulation 35).
These subcategories will apply to the obligations in the provisions relating to the producer responsibility to pay disposal fees in Year 3 (2027 to 2028), under Part 5, Chapter 3 of the Regulations.
These sub-categories will not apply to recycling obligations in Year 3 (2027 to 2028) assessment year under regulation 40.
The sub-categories are applicable to reporting for household and commonly binned or littered items of packaging as required to be reported under schedule 4 paragraph 6 (household packaging) and paragraph 10 (commonly binned or littered packaging) of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.
Year 4: 2028 to 2029 disposal fees
In Year 4, PackUK intends to exercise its discretion to specify two sub-categories within the existing packaging category ‘plastic’ namely the sub-categories: rigid and flexible.
These sub-categories will be relevant to the obligations in the provisions relating to data reporting (under regulation 35) and to the obligations in the provisions relating to the producer responsibility to pay disposal fees.
The sub-categories will not apply to producer and recycling obligations (under regulation 40).
In Year 4 packaging and waste categories are:
- aluminium
- fibre-based composite
- glass
- paper and card
- plastic
- steel
- wood
- other
Packaging and waste sub-categories are:
- plastic – rigid
- plastic – flexible
Application
In Year 4, these sub-categories will only apply to large producers and compliance schemes reporting on behalf of large producers.
The sub-categories will apply to packaging supplied in the 2027 calendar year and are relevant to obligations in the provisions relating to record keeping (under regulation 34) and obligations in the provision relating to data reporting (under regulation 35).
These sub-categories will apply to the obligations in the provisions relating to the producer responsibility to pay disposal fees in Year 4 (2028 to 2029), under Part 5, Chapter 3 of the Regulations.
These sub-categories will not apply to recycling obligations in Year 4 (2028 to 2029) under regulation 40.
The sub-categories are applicable to reporting for household and commonly binned or littered items of packaging as required to be reported under schedule 4 paragraph 6 (household packaging) and paragraph 10 (commonly binned or littered packaging) of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.