PPWR packaging rules: two regimes in Northern Ireland

Reacting to: New packaging rules apply in Northern Ireland from 12 August (nibusinessinfo.co.uk) →

On Wednesday, the EU's Packaging and Packaging Waste Regulation started to apply. It applies to packaging placed on the Northern Ireland market. It does not apply to packaging placed on the market in England, Scotland or Wales. If you make anything that goes in a box, a bag, a jar or a tray, and you sell it here, the rules governing how that packaging is designed and labelled changed on 12 August. They did not change for a firm doing the same job in Carlisle.

It is the first Windsor Framework divergence that affects ordinary Northern Ireland manufacturers and food producers directly rather than through customs paperwork, and it affects costs. The EU regulation sets how your packaging must be designed, while a separate UK scheme, which still applies here, sets what you pay per tonne for it.

What changed on 12 August

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, was adopted by the European Parliament and came into force on 11 February 2025. It began to apply on 12 August 2026, replacing the previous Packaging and Packaging Waste Directive. DAERA describes it as a shift from a waste-focused framework to one placing greater responsibility on design, production and upfront compliance.

Much of it applies in Northern Ireland under the Windsor Framework. A Commission Notice sets out which parts do not. DAERA's split is explicit:

Applies in Northern Ireland — recyclability of packaging, labelling, and restrictions on single-use packaging.
Does not apply in Northern Ireland — re-use and refill targets, extended producer responsibility and deposit return scheme obligations, and recycling targets.

The obligations do not all arrive at once. Requirements come into force progressively between 2026 and 2030, and in some cases up to 2040, with the earliest provisions focused on compliance, documentation and preparatory measures. Packaging first placed on the Northern Ireland or EU markets from 12 August 2026 must meet the requirements that apply from that date, which include substances in packaging and reusable packaging.

Northern Ireland producers now follow two regimes

Producer responsibility and deposit return are carved out of PPWR in Northern Ireland because the UK-wide packaging extended producer responsibility scheme continues to apply here, with the Northern Ireland Environment Agency as your regulator.

A producer in Carlisle faces one packaging design standard, the UK one. A producer in Dundalk faces one, the EU one. A producer in Ballymena faces the EU standard on design and labelling, and the UK scheme on fees and reporting. Whoever specifies your packaging needs to design it to meet both.

What the UK scheme costs

Under the UK scheme you must collect and report packaging data if you have an annual turnover of £1 million or more and were responsible for importing or supplying more than 25 tonnes of packaging to the UK market in the previous calendar year, and you carry out a packaging activity. A business with turnover between £1m and £2m, or supplying between 25 and 50 tonnes, is a small producer with lighter obligations. Above both thresholds you are a large producer and you pay waste disposal fees — and those fees only apply to household packaging, commonly binned packaging and glass household drinks containers.

The base fees currently in force, published on gov.uk's fees guidance and last updated on 7 April 2026, are £423 a tonne for plastic, £196 for paper and card, £192 for glass, £266 for aluminium, £259 for steel, £461 for fibre-based composite and £280 for wood.

From Year 2, packaging design affects the fee. The Year 2 illustrative fees for 2026 to 2027, published by PackUK and Defra on 19 December 2025, introduce modulated fees for the first time, graded green, amber and red under the Recycling Assessment Methodology. Amber is the base rate. Red is set at 1.2 times amber in Year 2. Green is a discount whose size depends on the mix of material reported across the scheme.

Plastic — green £415, amber £455, red £545 per tonne.
Paper and board — green £190, amber £210, red £250.
Glass — green £185, amber £205, red £245.
Aluminium — green £245, amber £270, red £325.
Steel — green £260, amber £290, red £345.

Worked example: a Mid-Ulster food producer, 180 tonnes

Take an illustrative Mid-Ulster food producer, with figures chosen so the arithmetic is easy to follow. Its turnover is £3.4 million, so it is a large producer. It places 180 tonnes of household packaging on the market a year: 62 tonnes of plastic, 78 of paper and board, 22 of glass, 12 of aluminium and 6 of steel.

On the fees currently in force: £50,484.
On Year 2 illustrative amber rates: £54,080. That is £3,596 more for identical packaging, before any design decision is made.
If the plastic is graded red and everything else amber: £59,660.
If every material lands green: £49,120.

The gap between those last two figures is £10,540 in a single year, decided by what the packaging is made of and how it grades. On a six per cent net margin, that producer's profit is £204,000, so the packaging specification alone changes profit by 5.2 per cent. The total bill at amber, £54,080, is 26.5 per cent of that profit.

Redesigning packaging for both regimes

The usual response to a red grade is to redesign the component. For a Carlisle producer that is one test to pass: the UK Recycling Assessment Methodology, which sets the fee. For a Northern Ireland producer the same redesign also has to satisfy PPWR recyclability and labelling on the Northern Ireland and EU side, assessed by a different authority under a different methodology, on its own phased timetable.

In most cases, making a material more recyclable helps on both tests, but passing one does not certify you on the other. A costly mistake would be buying new tooling that improves your fee grade and then finding it does not meet the labelling or single-use provisions that phase in later. Packaging tooling is a capital cost written off over years, so check the design against both tests on paper before ordering anything. Our advisory services can help with that decision.

What to do this week

Settle whether you are obligated at all. Turnover of £1m or more, and more than 25 tonnes of packaging supplied to the UK market last calendar year. You must meet both tests to be obligated. The gov.uk guidance on who is affected and what to do sets out the packaging activities that count.
Split your tonnage by market. Northern Ireland and EU in one column, Great Britain in the other. Only the first column is inside PPWR. If your stock system cannot produce that split today, set it up first. Our bookkeeping work can record the split as transactions are entered.
Read DAERA's own page. The packaging and packaging waste guidance carries the Commission Notice, the regulation itself and the phased implementation timetable. Queries on PPWR in Northern Ireland go to singleuseplastics@daera-ni.gov.uk; queries on the UK producer responsibility scheme go to the Northern Ireland Environment Agency at packaging@daera-ni.gov.uk.
Ask your packaging supplier for the grade, in writing. Green, amber or red under the Recycling Assessment Methodology, component by component.
If you export to the EU, respond to the register consultation. The European Commission is consulting on the draft implementing rules for national registers of producers, and it is open until 10 September 2026.

What is still uncertain, and when you will know

Whether Great Britain follows. DAERA states that a decision on whether to align with PPWR across the UK has not yet been taken, and that a formal consultation process to consider regulatory consistency is being planned. No date for that consultation has been published. Until then the two regimes will continue to diverge, because PPWR obligations phase in through to 2030 and in some cases 2040.

The Year 2 fees are not final. The figures above are the illustrative set published on 19 December 2025. Confirmed Year 2 fees were expected in June 2026, following the 1 April 2026 reporting deadline for packaging supplied in 2025, and gov.uk's fees guidance still carries the 2025 base fees. PackUK is explicit that illustrative fees are likely to change significantly as producers submit more data and regulators monitor compliance. Budget on the amber column and treat green as a possible saving.

The requirements will change between now and 2030. Substances in packaging and reusable packaging apply now; recyclability and labelling provisions arrive on their own dates. Review your compliance again as each provision takes effect.

How we can help

Packaging fees now depend on design decisions that most producers rarely revisit, and Northern Ireland producers have to satisfy two authorities on the same packaging.

Our management accounts show packaging fees on their own line, separate from materials, so a £10,540 change shows up in time to act on it. Our cashflow and budgeting work models the amber and red cases before the tooling is ordered, and our Ballymena office covers the whole of Northern Ireland, including the cross-border and Windsor Framework detail.

AJ

Andy Jackson

Straight Talk. Real Solutions. Better Business. I'm here to make your business more efficient and client-focused — no fluff, just honest advice and real results. I'm not here to waste your time with fancy buzzwords or unrealistic promises. I work with businesses that want straightforward, practical advice on how to improve. I'm passionate about creating real impact through digital transformation, improved processes, and a laser-focus on client experience. andyjackson.com

Business Pulse

Business Pulse is our advisory service for planning the year, tracking performance and making better decisions. Every month or quarter you see where the business stands against the plan, and you leave the review knowing what to do next.

From £299 + VAT a month, including your accounts and tax returns.

About Business Pulse

Tax and rule changes by email

We email when a tax rule, rate or deadline changes, with who it affects and what it costs. Unsubscribe in one click.

Common questions

Do the new packaging rules apply to my business in Northern Ireland?

They apply if you place packaging on the Northern Ireland or EU market. That is the test, and it is about the market you supply rather than where you are based. A Ballymena manufacturer selling into Belfast and Dublin is inside the Packaging and Packaging Waste Regulation for that packaging. The same manufacturer supplying a customer in Birmingham is outside it for that consignment, because the regulation does not apply to packaging placed on the market in England, Scotland or Wales. Separately, the UK-wide packaging producer responsibility scheme still applies to Northern Ireland businesses that pass its thresholds, so most obligated producers here now sit inside both.

What is the difference between PPWR and UK packaging EPR?

They regulate different things and are set by different authorities. The Packaging and Packaging Waste Regulation governs how packaging is designed and labelled, covering recyclability, labelling, substances in packaging, reusable packaging and restrictions on single-use packaging. UK packaging extended producer responsibility governs what you pay, charging obligated large producers a fee per tonne of household packaging placed on the market. The Commission Notice disapplies the producer responsibility and deposit return parts of PPWR in Northern Ireland so the UK scheme continues to run here.

I sell into Great Britain as well as Northern Ireland. Do I need two packaging specs?

Legally you could run two, because PPWR only bites on what you place on the Northern Ireland or EU market. Commercially, two specifications means two sets of tooling, two artwork files, two stock lines and a picking error waiting to happen. Most producers in this position will harmonise upward to the stricter specification across everything they make, and absorb the cost on the Great Britain volume where it buys no compliance benefit. That is a costing decision rather than a compliance one, and it is worth modelling properly before the tooling spend is committed, because packaging tooling amortises over years.

How much can packaging design actually change my EPR bill?

On the illustrative Mid-Ulster producer in this article, 180 tonnes of household packaging, the gap between everything landing green and the plastic component landing red was 10,540 pounds in a single year. Same volume, same customers, same tonnage. That is 5.2 per cent of the year's profit at a six per cent net margin, decided entirely by material choice and recyclability grade. Year 2 illustrative fees set red at 1.2 times the amber rate, so the penalty for a hard-to-recycle material is proportionate rather than punitive, but it compounds every year the packaging stays on the shelf.

When will we know whether the UK aligns with PPWR?

DAERA states that a decision on whether to align with PPWR across the UK has not yet been taken, and that a formal consultation process to consider regulatory consistency is being planned. No date for that consultation has been published. Until it runs and reports, the divergence between Northern Ireland and Great Britain is the operating reality, and it widens rather than narrows, because PPWR obligations phase in progressively between 2026 and 2030 and in some cases out to 2040.

Or get in touch and we will reply the same working day.

NI packaging now follows EU law while GB packaging follows UK rules