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Update on Labelling Requirement Under EPR

In a recent Defra ‘Business Readiness Forum’ webinar, Defra announced that the mandatory labelling regulation for all materials will be pushed back to April 2027

As part of the Extended Producer Responsibility for Packaging legislation, obligated producers are required to label all consumer packaging with the ‘Recycle’ or ‘Do not Recycle’ visual. Initially the deadline for businesses to include these labels on their packaging was 31st March 2026 for all packaging materials except films and flexible plastic where the deadline was 31st March 2027.

Defra have now announced that the labelling provision under EPR will now be pushed back to 31st March 2027 for all packaging materials.

The new regulations align with the format and principles of the OPRL label. Brands are required to conduct a recyclability assessment according to the methodology and guidance provided by the Scheme Administrator. Based on the assessment, brands must clearly label their products with ‘Recycle’ or ‘Do not recycle’ instructions and include the appropriate Recycle Now logo variants.

Recycling Labels

For packaging types that are not commonly collected from households for recycling but can still be recycled through other methods, additional recycling instructions must be provided to the consumer.

The regulations also specify the required sizes for symbols and fonts. For composite products, producers can either label one outer component or label each component individually.

If you are currently using the OPRL Recycle label and include appropriate instructions around disposal on your packaging, you are demonstrating compliance.

Earlier this year, OPRL revised its labelling guidelines to incorporate feedback from the EPR consultation released at the end of last year. These updates include a transition in the wording from “Don’t Recycle” to “Do Not Recycle”.

Additional modifications reflect the eligibility criteria for mixed polyolefin films, which can now be collected at front-of-store locations. Furthermore, products such as mono-polymer toothpaste tubes have been approved for the “Recycle” label, thanks to advancements in collection and sorting technologies.

Notably, the EPR reforms include an exemption for small businesses; however, this does not extend to labelling requirements. Manufacturers and retailers supplying packaging to entities with an annual turnover below £1 million and handling less than 25 tonnes of packaging annually are still obligated to implement the appropriate labelling on their products.

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