The strategy: will cover PackUK's objectives and the outcomes that it is aiming to achieve, along with how PackUK intends measure and report on the delivery of these objectives and outcomes.

The operational plan: will include priorities for the financial year starting on 1 April 2025, forecasts of disposal fees based on costs for both local authorities and public information campaigns, how disposal fees payable by liable producers will be calculated, and any communication activities that it expects to conduct in the following 12 months. 

pEPR Disposal Fees – base fee rates and future modulation 

The statement also provides an update on disposal fees. Under pEPR, the cost of collection and disposal of household packaging waste and packaging which commonly ends up in public bins is being moved to producers under the ‘polluter pays’ principle. 

In June 2025, PackUK are due to publish the final ‘base’ fee rates for the first set of disposal fees that producers will be invoiced from October 2025. These disposal fees will be based on producers’ 2024 packaging placed on market data and in this first year will be unmodulated. 

The second set of disposal fees (2026 fees, based on 2025 placed on market data) will be modulated based on the recyclability of the packaging, using the recently published Recyclability Assessment Methodology (RAM). This means the base fee will be modulated (i.e. increased or decreased) depending on the recyclability within the UK’s recycling infrastructure, to encourage producers to move to more recyclable packaging and reduce the amount of packaging placed on the UK market, to reduce packaging waste.  

Alongside PackUK’s statement on the final base fee rates due to be published in June 2025, we can expect a statement on the modulation of future disposal fees, which will explain how modulation will encourage the move to easier to recycle packaging and how the funds raised will support the UK recycling sector. 

Update: PackUK’s Operational Plan for the coming year 

The publication of the legislated Operational Plan by the scheme administrator has confirmed and outlined some key dates for producers to take note of: 

• Invoices are to be sent out to obligated producers in October 2025, outlining their costs in relation to disposal fees, administration costs and costs arising from public information campaigns. 
• 50 days after the invoice date, producers will have the choice to pay in full, or to set up quarterly instalments, expected to be made in November 2025, January, April, and June 2026. 
• In December 2025, the arrangement for modulated fees will be confirmed by PackUK, due to begin in 2026 based on producers’ 2025 placed on market data. 

Other statutory obligations outlined in the regulations that PackUK will need to carry out include the following activities: 

• June 2025: A statement of policy for the modulation of disposal fees. PackUK are aiming to publish this in June 2025 to give producers as much time as possible before the 2026 compliance year. 
• June 2025: PackUK will also publish its strategy which will outline it’s objective and functions, and the outcomes it intends to achieve 
• PackUK have an obligation to publish guidance to producers and local authorities on areas such as how fees are calculated, payments methodology and efficiency and effectiveness. 
• PackUK must also publish a list of packaging which is deemed to be ‘commonly disposed of in public bins or as ground litter’, which will be published when the necessary evidence has been gathered. 

 You can read the full policy statement here: UK joint policy statement on packaging Extended Producer Responsibility - GOV.UK  

We are here to support our members every step of the way during the pEPR reform, so if you have any questions or would like to share your thoughts with us, please contact your account manager or drop a line to our team on packaging@beyond.ly. We’ll be happy to discuss any issues you may have and how we can help.