The UK’s updated packaging producer responsibility rules take effect on 1 January 2026, refining how fees are calculated, how evidence is kept and how duties move when brands change hands. Parliament approved the instrument in December after it was laid on 3 November.

For year one of disposal fees, PackUK has confirmed base rates per tonne of household packaging placed on the market in 2024: plastic £423, paper and card £196, glass £192, aluminium £266, steel £259, wood £280, fibre‑based composites £461 and ‘other’ £259. These rates set the starting point before any future modulation.

Invoices for those 2025/26 fees began going out from October 2025 and are based on the 2024 data you filed with regulators. Payments are staged, but the liability itself is tied to last year’s tonnage by material.

A new closed‑loop offset is central to cost control in 2026. Large producers can deduct food‑grade plastic packaging that they collect from customers and have recycled back into food‑grade material by a single accredited reprocessor, provided they pay a £2,548 charge by 28 January 2026 and hold robust evidence. Claims are restricted to packaging first supplied on or after 1 January 2024.

What does that look like in pounds and pence? If a ready‑meal brand recovers and recycles 80 tonnes of PET trays as closed‑loop material, the offset could trim roughly £33,840 from its 2025/26 plastic bill at the base rate of £423 per tonne, before any future modulation. The offset only applies if the charge is paid and the evidence trail checks out.

For finance teams, timing still matters. Fees for 2025/26 are anchored to 2024 activity; future years will move to modulated fees that reward recyclability and design choices once the RAM methodology is embedded. PackUK’s year‑two (2026/27) illustration flags green/amber/red fee bands, with finalised rates expected after the April 2026 reporting cut‑off.

Mergers are no longer a grey area. When two producers merge, the combined entity takes on continuing obligations and unpaid liabilities for the year of the merger, must register promptly, and may inherit or transfer PRNs as appropriate. The rules are designed to stop obligations falling through the cracks when corporate structures change.

Brand and business transfers also carry new duties. Buyers must notify regulators within 28 days, re‑register if thresholds are met, and resubmit data for the two half‑year periods in the year of the transfer and the preceding year so fees land with the right owner. In practice, a brand acquisition can push a buyer into ‘large producer’ status for up to three years if turnover and tonnage thresholds are met.

Enforcement has sharper teeth. PackUK can identify missed liable producers and issue notices so costs are recovered from free riders, with interest charged on late payments stated in notices of liability. This is intended to level the playing field for compliant firms.

Definitions tighten too. Fibre‑based composites and paper/board are clarified, including a plastic‑layer threshold that can shift some items into the paper/card category for reporting and fees. Regulators signalled this approach in a 2025 position statement to give producers early clarity.

Case study: an online beauty retailer supplying 600 tonnes of plastic and 400 tonnes of paper/card in 2024 would face a base‑fee exposure near £253,800 for plastic and £78,400 for paper/card, around £332,200 before administration costs. If it builds a compliant closed‑loop stream of 100 tonnes of PET, the plastic element falls by c.£42,300, net of the £2,548 charge and any evidence costs.

What to do now. First, confirm whether closed‑loop activity is feasible for 2026 and arrange the £2,548 payment by 28 January with your regulator if you intend to claim. Second, refresh contracts for any 2026 brand-sale or business‑carve‑out to allocate EPR reporting, fee liability and evidence ownership explicitly. Third, review material choices ahead of modulation and document why each pack uses no more material than necessary.

Data discipline will be scrutinised. Keep source data and accreditation evidence from reprocessors and exporters in a way auditors can test. The official guidance stresses that closed‑loop claims will only count if the material is collected from your customers, kept separate from other waste and recycled back to food‑grade by a single accredited operator.

Finally, plan for volatility. Year‑two fees will reflect recyclability and could move materially by format and component. PackUK has already published the first illustration; the confirmed 2026/27 schedule will follow industry reporting in April 2026. Budget holders should scenario‑test outcomes before committing to 2026 packaging formats.