The UK’s Extended Producer Responsibility (EPR) for packaging, which began a phased implementation in 2023, is significantly changing packaging waste management by placing greater responsibility on producers. A key aspect of this policy is the new packaging labelling requirements, which aim to enhance recycling rates and improve consumer understanding.
As a compliance scheme, we understand the impact these changes will have on business operations and we are dedicated to offering guidance and support for a smooth transition to compliance. While not all details regarding EPR labelling requirements have been confirmed yet, we acknowledge that many producers are already preparing their businesses. To assist with these efforts, we have compiled a guide with the information currently available.
Mandatory Labelling: From 1st April 2027, all packaging (excluding plastic films and flexible packaging) will need to carry a clear label indicating whether it can be recycled or not. This label should also display the Recycle Now logo.
Defra has entered into a licence agreement with WRAP to use the Recycle Now logo on labels designed by Defra. This agreement will become active when the EPR labelling requirements come into effect. Producers will be able to use these labels at no cost.
Defra will offer two labelling options:
- ‘Recycle’
- ‘Do not recycle’
The pictograms for these labels have not yet been released and cannot be utilised until this element of the EPR regulations are officially implemented.
Responsibility: Brand owners and importers are primarily responsible for ensuring correct labelling on their packaging. Distributors have a duty to provide information about packaging recyclability to smaller businesses.
OPRL: The On-Pack Recycling Label (OPRL) scheme is currently voluntary but is likely to become the standard labelling system for packaging in the UK.
Enforcement: The Office for Product Safety and Standards (OPSS) will be responsible for enforcing the EPR regulations, including labelling requirements.
Areas of Uncertainty
Specific labelling guidelines: While the basic requirement for a “recycle” or “do not recycle” label is clear, detailed regulations regarding label placement, size, font, and other visual aspects are still awaited.
Exemptions: The exact criteria for exempting small businesses or specific packaging types from the mandatory labelling requirements have not been fully defined.
Enforcement mechanisms: The specific penalties for businesses that fail to comply with the labelling regulations are still under development.
Detailed Breakdown of Labelling Requirements
Mandatory Labelling: All packaging (excluding specified exceptions) must feature a prominent and easily understandable label stating whether it can be recycled. The Recycle Now logo must accompany the label.
OPRL Scheme: The OPRL scheme provides detailed guidelines for packaging labelling, including clear and consistent labelling, easy-to-understand symbols, and information about recycling processes. It is expected to become the standard labelling system.
Responsibilities: Brand owners and importers bear the primary responsibility for ensuring accurate labelling on their packaging. Distributors must provide information about packaging recyclability to smaller businesses, which may have some flexibility in labelling, depending on the final regulations.
Implications for Business
Compliance: Businesses should familiarise themselves with the basics of EPR labelling requirements to ensure preparation for compliance by the 1st April 2027 deadline.
Packaging Review: Existing packaging should be assessed to determine if it meets the new labelling standards. Changes to packaging design or materials may be necessary.
OPRL Membership: Joining the OPRL scheme can provide valuable guidance and support in meeting labelling requirements. Find out more about membership fees here.
Consumer Education: Clear and accurate labelling is essential for educating consumers about recycling. Businesses may need to implement additional communication strategies to support recycling efforts.
Stay Updated: Businesses should monitor for updates to the EPR regulations and labelling guidelines as they are developed.
Conclusion
The UK’s packaging EPR labelling regulations are a significant step towards improving recycling rates. While the core principles are clear, businesses should stay informed as details are finalised. By understanding the requirements and planning accordingly, companies can ensure compliance and contribute to a more sustainable future.
If you have any further questions, please don’t hesitate to reach out to our team of compliance experts to discuss your specific business circumstances. If you are a Comply with Clarity member and need additional information, you can either use the form below or contact your compliance manager directly.