The UK will strengthen its recycling efforts by introducing mandatory packaging recycling labels from 2026. As part of the Extended Producer Responsibility (EPR) program, the program aims to guide consumers towards better disposal of packaging materials.
Phase I
Beginning March 31, 2026
Recyclability labels are required on all primary and shipping packaging, except for plastic film and flexible packaging.
Phase II
Beginning March 31, 2027
The requirement extends to all types of packaging, and it is expected that progress will be made in the recycling of complex materials.
How is the EPR packaging recycling label fulfilled in the UK?
There are two options for the use of labels for packaging recycling:
01
Use DEFRA-designed labels:
Defra has entered into a license agreement with WRAP to use the Recycle Now logo on Defra-designed labels. The license agreement will come into effect when the Extended Producer Responsibility Main Ordinance comes into force, which is expected to be in mid to late 2024. This means that the labels will be applied free of charge to producers when the Extended Producer Responsibility Main Ordinance is fully implemented.
Defra has only 2 tab options, and they are explanatory only:
"Recycling."
"Don't recycle."
The label pictograms have not yet been published and cannot be used until the Extended Primary Producer Responsibility Regulation comes into effect.
02
Use the On-Pack Recycling Label (OPRL) label:
OPRL is a well known labeling scheme that utilizes the Recycle Now logo in the existing license agreement with WRAP. Producers can join the labeling scheme as members before pEPR requirements and Defra labels become available.
OPRL has a recyclability tool that allows manufacturers to select appropriate recycling labels for their packaging, as well as a variety of labels to help consumers decide what to do with their packaging, for example:
"Recycling."
"Don't recycle."
"Recycling in bags at large supermarkets."
"Widely recycled at recycling centers."
Producers can become members of the OPRL and use these labels immediately.
What is the impact on cross-border e-commerce sellers?
The new recycling labeling regulations will have a significant impact on the e-commerce industry. Online retailers and brands that ship or sell products within, to or from the UK will need to ensure that their packaging complies with the new requirements. This may result in a redesign of packaging design and materials to ensure compliance and avoid potential penalties.
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