Your Packaging Is Now Illegal Without These Labels — EPR Rules In Force Today

From 1 April 2026, placing new rigid packaging on the UK market without approved recycling labels is a breach of Extended Producer Responsibility regulations. The Plastic Packaging Tax also rose to £228.82 per tonne today. Most small product retailers, food businesses, and e-commerce operators have no idea these changes are in force.

This is what you need to know — and what to do before your next stock order.

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What Changed on 1 April 2026?

Two packaging regulations took effect today:

1. EPR Recycling Label Requirement

New rigid primary and transit packaging placed on the UK market must carry approved recycling labels from today. "Rigid packaging" covers most product packaging — plastic bottles, rigid plastic containers, cardboard cartons, glass, aluminium tins, and mixed-material packaging.

The approved label scheme uses the Recycle Now system, which provides standardised "check locally," "don't recycle," and "recycle" labels for each material type.

2. Plastic Packaging Tax (PPT) Rate Rise

PPT rose from £217.85 to £228.82 per tonne today — a 5% increase. The tax applies to plastic packaging manufactured in or imported to the UK that contains less than 30% recycled plastic content.

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Who Is Affected?

EPR recycling label requirement applies to:

• Product retailers placing goods in new rigid packaging on the UK market
• Food and drink manufacturers and importers
• E-commerce businesses using branded packaging
• Any business that sells physical products in packaging they are responsible for placing on the market

Plastic Packaging Tax applies to:

• Manufacturers producing plastic packaging components in the UK
• Importers of plastic packaging or goods in plastic packaging
• Any business using 10+ tonnes of plastic packaging per year

If you import products, you may be responsible for PPT on the packaging even if the product was manufactured abroad.

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The Label Requirement in Detail

Which Packaging Needs Labels?

The April 2026 requirement applies to new stock of rigid packaging. Key categories:

• Rigid plastic (HDPE bottles, PET containers, polypropylene tubs, rigid trays)
• Glass (bottles, jars)
• Aluminium and steel (tins, cans, aerosols)
• Paper and card (cartons, cardboard boxes used as primary packaging)
• Multi-material laminated packaging

Flexible packaging (film pouches, bags, wrapping) has different implementation timelines.

What Labels Are Required?

Labels must follow the On-Pack Recycling Label (OPRL) scheme guidance:

• "Recycle" — packaging that is widely recycled at kerbside
• "Check locally" — recyclable but with variable local authority provision
• "Don't recycle" — packaging that cannot be recycled in standard streams

Each packaging component (lid, body, label) may carry a different instruction. You need to check recycling guidance for each material layer.

Where to get labels: OPRL (oprl.org.uk) provides the official label artwork, usage guidelines, and licencing information.

What About Existing Stock?

The requirement applies to new packaging. Existing stock that was already labelled (or was manufactured before April 2026) is not immediately affected — you can sell through it. But any new packaging orders placed from today must include compliant labels.

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RAM Fee Modulation — The Hidden Cost from 2026/27

Beyond today's changes, the EPR framework introduces Recycled Content and Alternative Materials (RAM) fee modulation from the 2026/27 scheme year.

This is the mechanism that will most affect your packaging costs:

Packaging recyclability	Fee multiplier
Highly recyclable (meets threshold)	0.8x (lower fees)
Recyclable	1.0x (baseline)
Partially recyclable / "check locally"	1.2x (higher fees)
Non-recyclable ("don't recycle")	2.0x (double fees)

In practice: a product currently using non-recyclable laminated pouch packaging will face double the EPR producer fees from 2026/27 compared to a product in easily recyclable packaging.

For businesses with high packaging volumes, this fee differential may be larger than the cost of switching to recyclable alternatives.

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Plastic Packaging Tax — What's New at £228.82/tonne

The PPT rate increase today is modest (£11/tonne), but the compliance obligations haven't changed:

Who must register for PPT:

• Any UK manufacturer or importer who has manufactured or imported 10+ tonnes of plastic packaging in any 12-month period

PPT exemptions (30% recycled content):

• If your plastic packaging contains ≥30% recycled plastic by weight, it is exempt from PPT
• You must be able to prove this with supplier certification

Returns:

• Quarterly returns to HMRC
• Records must be retained for 6 years

If you're importing products in plastic packaging for UK sale and you haven't considered PPT liability, this is worth checking urgently. HMRC can recover PPT on goods that entered the UK without payment of the tax.

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Action Checklist for UK Businesses

Immediate (by your next packaging order):

• Identify which products you place on the UK market in new rigid packaging
• Check current labels against OPRL guidance — are they present and accurate?
• Contact your packaging supplier to confirm compliance on new stock
• Register at oprl.org.uk for label artwork and licencing (free for non-members, licensed for commercial use)

Before your 2026/27 packaging review:

• Assess which packaging materials will face fee modulation
• Request EPR recyclability classifications from your packaging manufacturer
• Model the fee impact of switching to recyclable alternatives
• Ensure PPT registration is in place if you're at or near the 10-tonne threshold

Ongoing:

• Retain records of all packaging placed on market (volume, material, recyclability)
• Submit EPR data to your scheme operator as required (annual data collection is live)
• Pay quarterly PPT returns if applicable

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How ComplianceAlert Helps

ComplianceAlert monitors DEFRA EPR guidance, OPRL label scheme updates, and HMRC PPT changes. When the fee modulation rates are confirmed, the label requirements expand to flexible packaging, or HMRC updates PPT thresholds and rates, you receive a plain-English alert.

For product businesses, staying ahead of EPR changes is increasingly important — the fee modulation system means packaging choices made now directly affect costs from 2026/27 onwards.

Not sure if your business is compliant? Take our free 3-minute Compliance Score quiz: 👉 compliancealert.co.uk/compliance-score

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Key Takeaways

• EPR recycling labels are mandatory from today (1 April 2026) for new rigid packaging
• Use the OPRL scheme for compliant label artwork
• Plastic Packaging Tax rises to £228.82/tonne from today — 30% recycled content threshold unchanged
• RAM fee modulation from 2026/27: non-recyclable packaging faces 2x the EPR fees
• Existing stock is not immediately affected — but new packaging orders must comply

👉 Start your free 7-day trial at compliancealert.co.uk — plain-English regulatory alerts for UK businesses.

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