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PRACTICE NOTES
Packaging and packaging waste extended producer responsibility The extended producer responsibility (EPR) regime for packaging is designed to move the full cost of dealing with packaging waste from households to packaging producers (applying the ‘polluter pays principle’), giving producers responsibility for the costs of their packaging throughout its lifecycle. Producers will pay less for sustainable packaging, incentivising packaging that uses less material and is easier to recycle. This is an evolution from the original producer responsibility regime provided for by the Producer Responsibility Obligations (Packaging Waste) Regulations 2007, SI 2007/871, in England and Wales. EPR is regulated through the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, SI 2024/1332 (as amended). From 1 January 2026, these regulations revoke the Producer Responsibility Obligations (Packaging Waste) Regulations 2007. This Practice Note is part of a suite of content on extended producer responsibility for packaging waste including the following: • Packaging design and use • Packaging waste—reprocessing and exporting • Packaging waste—compliance schemes • How to comply with the extended producer responsibility regime for packaging waste, as
NEWS
Law360: Bunzl Plc said on 28 May 2024 it has completed its purchase of 80% of food service distributor Nisbets for an initial payment of £339m, after receiving regulatory clearance for the transaction.
PRACTICE NOTES
The Packaging (Essential Requirements) Regulations 2015 (PERR 2015) govern packaging product design compliance in England and Wales. PERR 2015 require producers to design packaging that is minimised, recyclable and within substance limits. These regulations are complemented by the extended producer responsibility regime (EPR) in England and Wales which applies later in the lifecycle of packaging, and requires producers to account for the environmental impact of packaging waste and pay for its waste management. Extended producer responsibility fee modulation is based on recyclability content of packaging and so the PERR 2015 requirements to use recyclable and minimal packaging have a direct impact on EPR fees. For more information on EPR for packaging and packaging waste, see Practice Note: Packaging and packaging waste—extended producer responsibility regime. From a practical point of view, the plastic packaging tax introduced in April 2022 and applicable to plastic packaging that contains For more information on plastic packaging
PRACTICE NOTES
Background and purpose of deposit return schemes A deposit return scheme (DRS) places a refundable deposit on an in-scope drinks container when the packaged drink is supplied. The deposit passes through the supply chain and is repaid when the empty container is returned to an authorised collection point. Deposit return schemes are intended to reduce litter, increase the collection and recycling of drinks containers and produce a reliable stream of high-quality material for closed-loop recycling. In Wales, the statutory purposes also expressly include sustaining and increasing the reuse of returned containers. Separate statutory schemes will operate in England and Wales from 1 October 2027. Although their principal features are similar and both form part of the wider reforms to packaging waste regulation, their scope and detailed requirements are not identical. Businesses supplying drinks across both jurisdictions will therefore need to identify the destination market and apply the correct rules to each product line. For more information on plastic waste, see Practice Note: Waste types and controls—plastics. For more information on the extended producer responsibility regime relating
PRACTICE NOTES
A compliance scheme is an organisation that provides a service for producers who join the scheme, by taking on their legal obligations including registration, data submission and meeting recovery targets. Each compliance scheme is product specific. In England and Wales compliance schemes exist for packaging waste, WEEE and batteries. This Practice Note looks at the regulation of packaging waste compliance schemes under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. It forms part of a suite of content of packaging and packaging waste including: • Packaging and packaging waste—extended producer responsibility regime. • Packaging waste—reprocessing and exporting • Packaging design and use Packaging waste compliance scheme The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, SI 2024/1332, (as amended) implement the extended producer responsibility (EPR) regime for packaging and packaging waste in England and Wales. From 1 January 2026, they revoke and replace the Producer Responsibility Obligations (Packaging Waste) Regulations 2007. Compared with the 2007 Regulations, the 2024 regulations are significantly more onerous. Under the 2007 regime, compliance schemes were required to keep records and
PRACTICE NOTES
Extended producer responsibility regime The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, SI 2024/1332, as amended by the Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025, revoke and replace producer obligations under the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 from 1 January 2026. These 2024 regulations implement the extended producer responsibility (EPR) regime for packaging and packaging waste in England and Wales. While the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 primarily impose obligations on producers of packaging and packaging waste, they have implications for reprocessors and exporters in their role in verifying recycling outcomes and ensuring compliance across the packaging waste chain. They also impose specific obligations on reprocessors and exporters, for example mandatory registration and data submission requirements. This Practice Note forms part of a suite of content on packaging and packaging waste including: • Packaging and packaging waste—extended producer responsibility regime • Packaging design and use • Packaging waste—compliance schemes • How to comply with the extended producer responsibility regime for packaging waste, as a local authority Reprocessors
GLOSSARY
A service involving the transmission of data in the form of discrete blocks (packets) of information and, if necessary, the assembly and disassembly of data in this form.
GLOSSARY
Message-delivery technique in which packets are relayed through stations in a network.
NEWS
Law360, London: The owner of Paddington Bear has won a temporary injunction against a London souvenir distributor it has accused of copyright infringement, weeks before it is set to launch a new musical.
PRACTICE NOTES
Also produced in partnership with contributions from Marylis Clerc of Bird & Bird and Sapna Palla of White & Case LLP What are paediatric medicines and why do we need them? Paediatric medicines are medicinal products for use in children from birth until (but not including) the age of 18. In the past decades, little to no research and development into paediatric medicines took place. Many medicines were indeed not studied nor authorised for paediatric use, thereby forcing physicians to adapt dosage and form of medicinal products for the adult population based on their personal experience. It should not cause surprise that such large-scale off-label use entailed an increased risk of ineffective treatment and adverse reactions in children. A report from the European Medicines Agency (EMA) describes that while little data is available, harm did occur and was often underreported. There are several reasons for the lack of research and development of paediatric medicines, such as the fact that it
PRACTICE NOTES
This Practice Note sets out the different page limit requirements for bundles and documents in relation to financial remedy proceedings as provided for in the Family Procedure Rules 2010 (FPR 2010), specifically FPR 2010, PD 27A, both before and after the amendments to FPR 2010, PD 27A in effect from 2 March 2026, by way of comparison. It also sets out the requirements in the Financial remedies guide (March 2026) (the FRG) which merged and incorporated the below High Court judge level efficiency statement (dated 11 January 2022) and the High Court judge level efficiency statement (dated 1 February 2016). FPR 2010, PD 27A (Family proceedings: court bundles) An amended FPR 2010, PD 27A, replacing FPR 2010, PD 27A was published in November 2025 (within the sixth FPR 2010 PD Update of 2025). The amended FPR 2010, PD 27A is in force from 2 March 2026. FPR 2010, PD 27A must be complied with. See News Analysis: New FPR 2010, PD 27A on bundles—what are the main changes? Bundles in financial remedy proceedings are subject to different
PRACTICE NOTES
This Practice Note sets out the different page limit requirements in relation to all proceedings other than financial remedy proceedings as provided for in the Family Procedure Rules 2010 (FPR 2010), specifically FPR 2010, PD 27A, both before and after the amendments to FPR 2010, PD 27A in effect from 2 March 2026, by way of comparison. FPR 2010, PD 27A (Family proceedings: court bundles) An amended FPR 2010, PD 27A, replacing FPR 2010, PD 27A was published in November 2025 (within the sixth FPR 2010 PD Update of 2025). The amended FPR 2010, PD 27A is in force from 2 March 2026. FPR 2010, PD 27A must be complied with. See News Analysis: New FPR 2010, PD 27A on bundles—what are the main changes? Bundles in all proceedings other than proceedings for a financial remedy are subject to different rules from those applicable to bundles in financial remedy proceedings, including as to overall page limits and the page limits for individual documents. For details of the bundle requirements in FPR 2010, PD 27A (depending