UK EPR regime could become truly performance‑based with data and innovation

A new white paper launched at The RECOUP Summit on 4 March argues that combining digital tracking, advanced sorting and verified data could make the UK’s Extended Producer Responsibility (EPR) regime genuinely performance‑based, rewarding companies that deliver real recycling outcomes.

Titled “EPR That Works: Incentivising Real Recycling with Data and Innovation,” the paper is produced by recycling technology platform Polytag and backed by compliance agencies Ecosurety and Valpak and retailers including Waitrose, M&S and Ocado Retail. It sets out proposals to move modulation of EPR fees from a largely design‑and‑material classification exercise towards a system driven by measured, verifiable end‑of‑life performance.

The current policy context makes the argument urgent. Producers have been required since 1 March 2023 to record and report the amounts and types of packaging they supply, with more frequent reporting obligations for larger businesses, according to Ecosurety. The UK’s recyclability assessment framework , the Recyclability Assessment Methodology (RAM) finalised by Defra and the EPR scheme administrator , came into force on 1 January 2025 and classifies household packaging as green, amber or red based on recyclability and the available collection infrastructure. Defra has also published illustrative base fees for packaging, calculated using 2022 packaging data, while the timetable for fee introduction has been subject to change and industry discussion. Ecosurety notes that illustrative base fees were released in advance of final rates, which will be confirmed once further data is available. Defra has at times reaffirmed original timelines but also delayed implementation of certain waste management fees to allow further engagement with stakeholders. According to Ecosurety, some fee measures have been postponed to October 2025 while data reporting duties remain in force.

Polytag’s paper frames those regulatory building blocks as an opportunity to embed practical accountability. Alice Rackley, CEO of Polytag, said: “The system doesn’t currently reward businesses that actively drive recycling performance. Emerging innovations are changing the way we see, report and act across the packaging value chain. Beyond recyclability, these innovations form the foundation for circular economy intelligence.” Catherine David, CEO of WRAP, told the summit that digital technologies can accelerate packaging circularity and that the UK Packaging Pact, launching in April, will rely on improved data capture to support eco‑modulation under EPR.

At the technical level the white paper highlights four classes of capability it says can be brought to bear. Data analytics and sensor feeds to anticipate and optimise material flows; next‑generation optical or material sorting able to distinguish polymer types, food‑grade suitability and brand ownership so materials can be kept in higher‑value loops; invisible ultraviolet tagging to permit item‑level end‑of‑life tracking and provide real‑time, barcode‑level recycling metrics; and lifecycle impact reporting that links verified recycling figures to carbon accounting and corporate ESG disclosures.

The proposal for an additional voluntary tier, dubbed “Green Plus”, would sit alongside the existing modulation framework and deliver lower fees or other commercial recognition for producers that demonstrate verified improvement in recyclability, recovery and transparency. Will Ghali, CEO of Ecosurety, said: “We are at a pivotal moment for EPR. Innovation and data give us the chance to connect design, behaviour and real recycling outcomes in a way that simply wasn’t possible before.” Steve Gough, CEO of Valpak, argued a Green Plus approach could move the system beyond minimum compliance by acknowledging brands that invest in measurable circular solutions.

Retailers supporting the paper stress commercial benefits as well as environmental ones. Laura Fernandez, Senior Packaging and Sustainability Manager at Ocado Retail, said: “Access to reliable, real‑world data helps retailers understand which packaging models deliver genuine environmental benefit. That evidence supports confident decision‑making, whether improving recycling performance or exploring reuse and return models at scale.” The paper positions such evidence as essential if modulation introduced from 2026 is to reflect actual environmental performance rather than proxy classifications alone.

The proposals come amid policy divergence within the UK. The Welsh Government is consulting on rules that could require packaging producers to fund litter and public bin waste management from 2027‑28, extending the scope of producer obligations in Wales relative to England. That regional variation underscores the challenge of creating modulation that is both fair to businesses and sensitive to different collection infrastructures.

Industry groups and compliance bodies have already prepared guidance to help producers navigate EPR. Ecosurety has developed online resources and hubs, and its communications stress that reporting duties and readiness remain priorities even where fee implementation has been adjusted. Meanwhile, RAM’s green/amber/red classifications mean some formats , for example packaging with embedded electronics or containing PFAS , may be automatically graded as hard to recycle without additional intervention.

Polytag and its partners present the paper as a practical road‑map for integrating innovation into modulation design, but their recommendations raise implementation questions. Rolling out item‑level tracking and higher‑resolution sorting at municipal scale will require capital investment, data standards and likely regulatory decisions about verification and audit. The white paper acknowledges those barriers and sets out verification and transparency mechanisms intended to prevent greenwashing, while arguing that industry and government collaboration can lower costs and scale innovations more quickly.

For businesses engaged in industrial decarbonisation and packaging strategy, the paper signals a possible shift in how environmental performance will be monetised under EPR. If the Green Plus approach is taken forward, firms that invest in measurable circularity could see lower fee exposure and tangible value from improved sorting, tracking and design. Policymakers and industry will need to align on verification standards, data governance and the timetable for translating measured outcomes into modulation if that potential is to be realised.