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UK Introduces Recycling Labelling Requirements for Packaging Producers

Once the draft regulation titled The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 is approved, designated producers shall conduct recyclability assessment for all primary packaging and shipment packaging they supply. Starting from April 1, 2027, designated producers shall additionally ensure that such packaging complies with the stipulated recycling labelling requirements.

On May 1, 2024, UK notified WTO of a draft regulation titled The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. The provisions under the notification process are outlined in Chapter 2 under Part 3 of this draft, which impose recycling labelling requirements on packaging producers established in the UK. The draft is now open for comments until June 30, 2024, and scheduled to come into force on January 1, 2025.1

Extended Producer Responsibility (EPR) is a globally adopted policy that encourages producers to make sustainable decisions during product design, facilitating easier re-use and recycling at the product's end of life. The UK's EPR scheme encompasses a packaging producer responsibility system, where the UK government intends to reform regulations to further enhance resource efficiency and waste reduction. In the notified Chapter, UK outlines the obligations for designated producers, and provides detailed requirements for mandatory recycling labelling on the packaging.

Scope and Obligations for Designated Producers

Packaging producers, including brand owners, packers/fillers, importers, and first UK owners (the first entity established in the UK that takes ownership of a non-imported packaging in the UK), bear the main labelling obligations stipulated in the notified Chapter. Under its provisions, these designated producers shall:

  1. Determine the recyclability of any primary packaging and shipment packaging they supply in accordance with Regulation 27, and keep the assessment records for a minimum of seven years;

  2. Ensure that any primary packaging and shipment packaging they supply complies with the stipulated recycling labelling requirements starting from April 1, 2027.

Regarding the applicable primary packaging and shipment packaging supplied by designated producers, they are required to have a largest surface area of at least 25 cm2, excluding exempt packaging specified in Regulation 11(1) and drink containers made of any material other than glass.

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Labelling Requirements

1. Content requirements

The recycling information required to be labelled on the packaging includes a statement and a symbol indicating the packaging's recyclability, along with any relevant recycling instructions. These elements are required to appear together on the packaging in a visible and legible manner. Detailed requirements for these elements are presented in the table below:

Recyclability Assessment ResultsRecyclability Information to be LabelledRecycling Instructions* to be Labelled
The packaging is not recyclable.- The phrase "Do Not Recycle"; and

- The following symbol:

do-not-recycle.png

/
The packaging is recyclable.

- The phrase "Recycle"; and
- The following symbol: recycle-3.png

The instructions on how to dispose of the packaging waste for recycling, other than through household collection by a relevant authority.
Notes:

* The producer shall include recycling instructions on the label if the recyclability assessment has determined that:

- The packaging is not widely collected for household recycling by authorities; and
- Other recycling disposal methods exist for the packaging's recycling.

2. Specification requirements

The notified Chapter sets specification requirements for the recycling information to be labelled on the packaging. The requirements vary based on the packaging's dimension. Specifically, 

Packaging DimensionSpecifications
If the surface area of the packaging's largest surface is ≥ 80 cm2

- Words must be displayed in a font where the x-height* of the letters is at least 1.2 mm; and

- The symbol should have a minimum height of 9.5 mm when displayed in portrait orientation, or 3.5 mm when displayed in landscape orientation.

If the surface area of the packaging's largest surface is < 80 cm2- Words must be displayed in a font where the x-height* of the letters is at least 0.9 mm; and
- The symbol should have a minimum height of 7 mm when displayed in portrait orientation, or 3.5 mm when displayed in landscape orientation.
Notes:
* "x-height" refers to the height of a lower-case letter which does not extend above or below the line, such as "x".

3. Other requirements

In addition to the general labelling requirements mentioned above, the notified Chapter introduces specific requirements for special cases as follows:

a. A producer supplying medical packaging can include the recycling information on a leaflet accompanying the product or device inside the packaging, or provide it electronically to the intended recipient.

b. A producer supplying unbranded filled packaging should either label the recycling information directly on the packaging, or on an attached label. For online sales, the recycling information should be displayed in the product description. For offline sales, the recycling information must be prominently displayed at the point of purchase.

c. Where a product's primary packaging consists of multiple components or ancillary elements, the producer should either label the recycling information on the outer or main component to indicate recyclability of each component, or label each component individually with its recyclability status.

d. Where a producer becomes aware that any packaging supplied by the producer has not been correctly labelled, the producer shall take reasonable steps to correct the error. 

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