A complete packaging compliance checklist

A complete packaging compliance checklist


Packaging regulations are evolving at record speed. From Extended Producer Responsibility (EPR) to the Plastic Packaging Tax (PPT), Deposit Return Schemes (DRS) and the EU Packaging and Packaging Waste Regulations (PPWR), compliance is no longer just a legal requirement, it’s a daily operational challenge.

At the same time, sustainability reporting frameworks like the Corporate Sustainability Reporting Directive (CSRD) and the Task Force on Climate-related Financial Disclosures (TCFD) are pushing packaging into the boardroom. Packaging choices now directly influence climate risk, financial disclosures and brand reputation.

This complete packaging compliance checklist breaks down the key UK and EU regulations, explains what they mean in practical terms and outlines the steps your business should take now.

Why packaging regulations are tightening

Governments across the UK and EU are working towards the same objectives:

  • Reduce waste and litter, particularly plastics
  • Improve recycling rates and transition towards a circular economy
  • Shift the cost of packaging waste management away from councils and back to businesses
  • Increase transparency around sustainability and climate impact

If your organisation places packaging on the market, you’re now more accountable than ever for its entire lifecycle.

Key packaging legislations in the UK and Europe

Below is your at-a-glance overview of the major packaging rules shaping business strategy today.

Extended Producer Responsibility (EPR or pEPR) and Recyclability Assessment Methodology (RAM)

In the UK, EPR represents a significant overhaul of packaging waste rules. Under EPR, businesses that place packaging onto the market must:

  • Collect and report packaging data (weights, materials, formats)
  • Pay the full cost of collection, recycling and disposal
  • Bear charges structured around recyclability, driving design change

RAM (Recyclability Assessment Methodology) sits within EPR and measures how recyclable packaging actually performs in real UK recycling systems. Packaging that is harder to recycle will attract higher fees whilst easier-to-recycle formats will be financially favourable.

What this means for your business:

  • Accurate, up-to-date packaging data is essential
  • Packaging design must focus on real-world recyclability
  • Your costs will vary based on materials and performance
  • Supplier collaboration is critical to future-proof packaging

Whether you operate solely in the UK or also export into the EU, understanding how recyclability is measured and modelled will help you control costs and minimise regulatory risk.

The UK Plastic Packaging Tax (PPT)

In force since April 2022, PPT applies to UK manufacturers and importers handling over 10 tonnes of plastic packaging annually.

If packaging contains less than 30% recycled content, it is taxed at £223.69 per tonne (the rate rises annually with CPI and is set to increase to £228.82 per tonne on April 1st 2026).

What this means:

  • Recycled content isn’t optional, its commercially sound
  • Businesses must track recycled content percentage accurately
  • PPT should be built into costing and pricing models

Deposit Return Schemes (DRS)

A Deposit Return Scheme (DRS) boosts recycling by placing a refundable deposit on qualifying drink containers, which consumers reclaim when they return the empty packaging to a collection point such as a retailer or reverse vending machine.

Europe:

Many European countries already have DRS systems in place and more are rolling them out in coming years. For example, Ireland’s national Deposit Return Scheme has been in force since 1 February 2024, initially covering PET plastic bottles and aluminium/steel cans between 150 ml and 3 litres. Consumers pay a small deposit at point of sale and reclaim it when returning empty containers, either via machines or manual collection points.

UK:

The UK is introducing DRS across the four nations with an anticipated implementation around October 2027. The scheme will see customers pay a small refundable deposit on eligible containers and receive the amount back when returned.

What businesses should consider:

  • Packaging design and labelling must meet DRS requirements
  • Operations may need to adapt for handling returns, storage and finance systems
  • Accounting must manage deposit flows, reconciliation and reporting
  • Market differences (Ireland live now vs UK regionally phased rollout) should be reflected in planning

EU Packaging and Packaging Waste Regulation (PPWR)

If you export to the EU or are based in the EU, understanding PPWR is essential. Effective August 2026 (with staged deadlines), it will create consistent rules across all EU countries.

Key requirements include:

  • Stricter recyclability criteria
  • Mandatory packaging minimisation and right-sizing
  • Reuse and refill targets
  • Controls on certain single-use and transport packaging
  • eCommerce packaging restrictions

A major rule of PPWR:

Transport and eCommerce packaging must not exceed 50% empty space, including when void fill is used.

For UK businesses selling into the EU, packaging must comply with both UK and EU rules, which may differ. If you are an EU business, there will be direct impact on your packaging strategies.

Sustainability Reporting: TCFD & CSRD

UK – Task Force on Climate-related Financial Disclosures (TCFD)

Task Force on Climate-related Financial Disclosures (TCFD) reporting requirements apply to many large UK organisations. It is mandatory for:

  • UK registered traded companies
  • Large UK registered private companies (turnover over £500m and over 500 employees)
  • UK registered LLPs meeting similar thresholds
  • UK regulated financial institutions

TCFD obligations are based on UK regulatory thresholds, not where the parent company is located.

This means:

  • EU companies with UK subsidiaries that meet the thresholds must report under TCFD.
  • EU companies without a UK legal entity (selling only into the UK) are not in scope.

Packaging decisions, including costs associated with EPR, PPT and DRS, feed directly into climate-risk disclosures and financial planning. Packaging also impacts Scope 3 emissions, which remain a key area of focus for investors and regulators.

EU – Corporate Sustainability Reporting Directive (CSRD)

The Corporate Sustainability Reporting Directive (CSRD) will significantly expand future ESG reporting across the EU and is expected to apply to a wide range of EU-based organisations, as well as some UK businesses with substantial EU operations.

Packaging contributes directly to CSRD reporting through:

  • Resource and material use
  • Waste reduction
  • Circular economy performance
  • Recyclability and recycled content metrics

How TCFD and CSRD Connect Across Markets

In practice, many businesses operating across the UK and EU may interact with both reporting frameworks:

  • TCFD for UK registered entities that meet UK thresholds
  • CSRD for EU based entities or UK companies with EU regulated activities

Together, these frameworks shape packaging strategy, influencing design choices, material selection, carbon impact analysis and cost management.

Checklist

  • Align packaging and sustainability reporting workflows (EPR, PPT, PPWR, CSRD, TCFD)
  • Avoid treating compliance and reporting frameworks as separate projects
  • Build governance and data systems that support consistent, cross-market disclosure

What should businesses be doing now?

To stay compliant and competitive, here is your actionable checklist:

Data and Reporting

  • Collect accurate data on materials, weights, recycled content and recyclability
  • Align reporting processes across EPR, PPT, PPWR and other sustainability frameworks

Design and Materials

  • Design packaging for recyclability and reuse
  • Increase recycled content where feasible
  • Minimise unnecessary packaging and void space

Operations

  • If appropriate, plan for DRS handling, reverse logistics and financial flows
  • Ensure labelling is compliant with scheme requirements

Strategy and Governance

  • Integrate packaging compliance with broader sustainability and risk reporting
  • Embed regulatory risks into corporate strategy and board reporting

Partnerships

  • Work with packaging suppliers and compliance specialists
  • Use external expertise to audit, optimise and future-proof packaging

How Macfarlane Packaging can help

With multiple regulations overlapping, compliance can feel overwhelming. Macfarlane Packaging helps businesses take a practical, data-led approach that turns regulatory pressure into opportunity.

Our experts can assess and optimise your packaging to increase recyclability and boost recycled content where viable.  This optimisation can also reduce material usage and pack weights, as well as streamline pack formats for faster fulfilment.  We also offer full reporting on packaging weights and material breakdowns, as well as percentage of recycled contents and RAM RAG ratings by product.

Regulations will continue to evolve and so will packaging. We partner with customers long-term to help review, refine and future-proof packaging strategies that balance protection, cost efficiency and sustainability.



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