Legislation Lookbook Autumn 2026
Products of Change | Legislation Lookbook
Welcome to the POC Legislation Lookbook A year on from the inaugural publication, environmental lawmaking is continuing to gather pace and direction, with some bodies of legislation reducing in scope, as others reveal their next level of complexity. Global events are necessitating heightened urgency while navigating this new landscape is both challenging, and also extremely necessary. This guide, created in partnership with the Global Licensing Group, brings together the key regulations impacting and enabling innovation and better practice in the brand and licensing industry, helping you see what’s coming and prepare with confidence. To keep up-to-date with key industry, technological, and legislative announcements throughout the year, sign up for the POC newsletter, or come join our growing community by scanning the QR code overleaf. Please be aware that this is guidance from the POC Community; we are not a legal entity so please do check with your legal specialists on your company obligations.
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Contents Brand owners Business model context Evolving disclosure requirements Key global requirements Takeaways for brand owners with licensed product POC guidance for calculating GHG emissions for brand licensing
6 6 6 7 10 12
Licensed manufacturers EU Green Deal Key legislation: EUDR Green Claims ESPR EPR (UK) EPR (EU)
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Products of Change closing remarks
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Products of Change is a not-for-profit membership organisation, dedicated to reducing the environmental impact of the brand and licensing industry through tools and connections to enable progress towards the 2030 climate goals.
www.productsofchange.com
www.productsofchange.com/news
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Change is here: what’s happening now and what’s coming next...
As you explore what is required and how those requirements will evolve over the next three years, you will see that every part of the industry is affected. Some businesses must report data directly, others will need to provide data to customers and partners through the supply chain. Collecting and sharing accurate data underpins these requirements. If you build the right systems now, you can collect information once, use it across multiple requirements and significantly reduce the reporting burden as expectations evolve. For some within the industry, such as brand owners, you may be required to disclose the environmental impact of your brand licensing business, others won’t (dependent on where your headquarters are located and the value of that business). For many licensed manufacturers and retailers, the majority of produced level data will be your responsibility, and it’s important that your brand owners are fully aware of the decisions you are having to make within your business, to enable you to create products that align to both regulation and brand guidelines. The objective is to simplify the burden and enable us to build systems that unlock and recirculate the value of a product – a new concept for our industry and one that we must embrace and learn how to earn from. The majority of environmental legislation has started, and will continue to roll-out over the next three years (to 2030), increasing in pace and complexity.
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2030 As the European Green Deal is setting the overall direction for climate neutrality by 2050 (with many elements having a 2030 deadline), we are first going to focus here. The EU’s ambitions are being implemented through separate laws with different scopes and dates. For brand owners, licensees, manufacturers and retailers, the practical task is to identify which duties apply directly and what evidence customers may need from their supply chains. This overview is selective, not a legal inventory. Level
Name
Meaning
Overarching strategy
European Green Deal
Policy direction, not one law or one compliance date.
Binding climate goal
European Climate Law
Climate neutrality by 2050; at least 55% net emissions reduction by 2030 against 1990.
Policy programmes
Fit for 55; Circular Economy Action Plan; REPowerEU; Biodiversity and Farm to Fork strategies
Packages and plans that have led to distinct legal measures.
Company obligations
CSRD and ESRS; CSDDD
Disclosure of material sustainability matters, and due diligence on certain key impacts for companies in scope.
Product and supply chain rules
ESPR; PPWR; EUDR; Forced Labour Regulation; CBAM; EU ETS
Requirements depend on product, commodity, activity and role in the market.
The above has created a cascade of legal frameworks, with multiple levers dependent on key elements; no one business will have the same requirements.
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Products of Change | Legislation Lookbook
Brand owners Business model context Many brand owners earn a significant share of their revenue by licensing their intellectual property (IP) to third-party manufacturers and distributors. These licensees design, produce, market, and sell products under contractual agreements, paying royalties tied to net sales. Although the brand owner doesn’t manufacture these licensed products directly, its financial performance is tightly linked to the sustainability practices of its licensees – affecting both brand equity and the stability of royalty income streams.
Evolving disclosure requirements Europe: Legislation such as the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) introduces double materiality, requiring brands to look both at their impact on the environment, and the environmental impact on their business across the entire value chain. Within the EU, you align to ESRS (the European Sustainability Reporting Standards) which include CSRD, CSDDD and much more. The EU’s Omnibus I amendments entered into force on 18 March 2026: CSRD reporting is now generally limited to EU companies with more than 1,000 employees and over €450 million net annual turnover, while qualifying non-EU groups face separate EU turnover tests (commission.europa.eu). From 26 July 2029, the amended CSDDD will generally cover EU companies with more than 5,000 employees and €1.5 billion worldwide turnover, and nonEU companies with more than €1.5 billion EU turnover; qualifying licensing arrangements have a separate test, and Member States must transpose the CSDDD changes by 26 July 2028.
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Outside Europe – key global requirements UK & Global Markets
2011
While these specific EU laws don’t apply outside of the EU, if you distribute into these markets you could be in-scope. Alongside this, brand owners are still expected to report against the International Sustainability Standards Board framework (ISSB) such as the International Financial Reporting Standards FRS S1 and S2, and the SASB (Sustainability Accounting Standards Board). Both are industry specific guidance for sustainability disclosures. These cascade behind FRS and are not fully aligned with ESRS, but are a good tool to navigate category specific risk and reporting. Many international companies are re-aligning their reporting to ESRS. For further guidance on consolidating you can head to: www.efrag.org/en/ news-and-calendar/news/ifrsfoundation-and-efrag-publishinteroperability-guidance To help showcase the two frameworks, please see the image opposite.
Global route
SASB founded
2015-2017
TCFD formed and recommendations published
2021
ISSB established by the IFRS Foundation
2022
CSRD adopted in the EU
2023
IFRS S1 and S2 issued
2023
First ESRS adopted
ISSB standards: IFRS S1 and S2 SASB supplies industry guidance
EU route
CSRD requires reporting under ESRS including climate standard ESRS E1 7
Products of Change | Legislation Lookbook
United Kingdom The UK has its own Sustainability Disclosure Requirements (SDR) that align with the above ISSB IFRS S1/S2 framework. UK Sustainability Reporting Standards (UK SRS) S1 and S2 were proposed in 2024 and were officially published in February 2026 by the Department of Business and Trade (DBT). However, as of 2026, this reporting is still voluntary. Within the UK, there are some businesses that are required to report their climate impact. Large listed businesses must make TCFD-aligned climate disclosures, while other companies may be brought into scope by their corporate status, employee numbers and turnover, with some large private companies covered when they exceed 500 employees and £500 million turnover.
International (global baseline) ISSB-based sustainability reporting is spreading across more than 45 jurisdictions, but adoption is determined locally by the companies covered, the extent of alignment with IFRS S1 and S2, and the start dates differ by market, this is not a mandatory requirement in all markets.
United States Unfortunately, on 29 May 2026, the Securities and Exchange Commission (SEC) proposed to reduce the amount of rules, meaning that climate disclosure will not be federally mandated in the US, resulting in ESG becoming investor driven and voluntary. Following this, as of 31 August 2026, Environmental Protection Agency (EPA) pushed back the US Renewable Fuel Standard (RFS) air pollution deadline compliance from the start of September 2026 to 31 March 2027. This year, the EPA has also put forward a rule to end data centre disclosure, in an attempt to make public disclosures for certain data centre emissions voluntary at state discretion. While the US Securities and Exchange Commission has proposed withdrawing its federal climate disclosure rules, California still requires companies with more than $1 billion in annual revenue that do business in the state to report greenhouse gas emissions, with Scope 3 reporting to follow; similar laws have been proposed in New York and New Jersey, while Illinois has a narrower climate risk disclosure rule for insurers.
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Asia-Pacific highlights Japan The Sustainability Standards Board of Japan (SSBJ) has now fully incorporated the ISSB standards (IFRS S1 and 2), with compliance being made mandatory for companies listed on the Tokyo Stock Exchange Prime Market, starting from the fiscal year ending March 2027. SSBJ also issued the practical sustainability disclosure ‘the practical standard’ on 11 June 2026, which outlines how companies can use Japan’s existing greenhouse gas reporting system to meet the SSBJ’s disclosure rules, ensuring that companies comply with the set standards.
China and Hong Kong In 2025, the Hong Kong Institute of Certified Public Accountants (HKICPA) issued the Hong Kong Financial Reporting Standards (HKFRS) S1 and S2 in line with the ISSB. These standards are continually updated, with the last update being 30 July 2026. In China, the Chinese Sustainability Disclosure Standards (CSDS) is in line with the ISSB and CSRD but has also incorporated ‘double materiality’ as of March 2026. This means that companies have to disclose both how their operations impact their own finances but also the environment and national targets.
Australia The Australian Accounting Standards Board (AASB) introduced mandatory climaterelated financial reporting from 2025, using AASB S2, its Australian adaptation of the ISSB’s IFRS S2 standard. Reporting is phased across three groups: the largest entities began with financial years starting in January 2025, Group 2 from July 2026 and Group 3 from July 2027. Grouping depends on company size or other specified reporting criteria; broader AASB S1 sustainability reporting remains voluntary. 9
Products of Change | Legislation Lookbook
Takeaways for brand owners with licensed products Royalty income and IP value are financially exposed to a licensee’s ESG performance. Even if headquartered outside of the EU, non-EU brand owners can fall within EU sustainability rules when their European business meets the relevant thresholds; under CSDDD, qualifying licensing arrangements have their own royalty and EU turnover test, so a licensed business cannot assume it is outside scope simply because its headquarters are elsewhere.
Risk areas
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Risk Area
Description of exposure
Potential financial impact Management/response
Reputation and brand equity
Licensees' practices on labour rights, sourcing, or environmental performance can impact consumer and stakeholder perception of the brand.
Brand equity erosion, reduced royalty revenue, cancelled agreements.
ESG clauses in licensing contracts; active partner audits; corrective action plans.
Regulatory compliance
Licensees must comply with expanding global regulations (e.g. EU CSRD, ESPR/DPP, EPR, CSDDD, CBAM, EUDR).
Risk of non-compliance fines, loss of retail channels, product bans, reduced sales.
Licensing standards aligned with global regulatory frameworks; dedicated compliance oversight team.
Climate transition risk
Products made under license may face increased costs due to carbon pricing, sustainable material requirements, or packaging restrictions.
Higher production costs for licensees, reducing demand and royalties.
Development of sustainable material guidelines; engagement with suppliers to explore circular solutions.
Physical climate risk
Licensee supply chains face risks from climate impacts (heat, flooding, extreme weather).
Supply disruptions reduce licensed product sales, lowering royalties.
Supply chain mapping, resilience planning, diversification of licensee production bases.
Consumer preference shifts
Increasing demand for sustainable, circular, and low-carbon products.
Misalignment could reduce sales and limit licensing opportunities.
New product development guidelines requiring circularity; co-branding with sustainability leaders.
Intellectual property value
Long-term brand value could decline if licensing business is associated with negative ESG impacts.
Potential write-down of IP assets; loss of long-term licensing pipeline.
ESG integration in brand management; continuous monitoring of brand sentiment.
Revenue concentration
Significant licensing revenues come from categories with higher ESG exposure (e.g. apparel, plastics, toys).
Royalty volatility; stranded revenues if categories face regulation or consumer backlash.
Diversification into lower-risk categories (e.g. digital content, services, sustainable product lines).
Waste and end-of-life
Licensed products may create significant waste (unsold stock, single-use plastics).
Retailer pushback, unsold goods impacting royalties, potential modulated EPR fees.
Collaboration with licensees on circular design; packaging transition programmes.
Comparing EU and UK Feature
EU CSRD
UK SDR / TCFD
Who is in scope
Following the 2026 simplification, generally EU companies with more than 1,000 employees and over €450 million net annual turnover. Separate tests apply to qualifying non-EU groups (www.consilium.europa.eu).
Specified listed companies, large companies and LLPs. Many large private companies are covered where they have more than 500 employees and over £500 million turnover (www.gov.uk).
What is reported
Material environmental and social impacts, risks and opportunities.
Climate-related risks and opportunities affecting the business.
Materiality
Double materiality: the company’s impact on people and the environment, and sustainability’s financial effect on the company.
Primarily financial materiality: how climate change may affect the company.
Standards in use
European Sustainability Reporting Standards Current requirements are TCFD-aligned. UK (ESRS), simplified in 2026 (finance.ec.europa.eu). SRS S1 and S2 are available for voluntary use; proposed listed-company rules would introduce UK SRS-based reporting from 2027, subject to the FCA’s final decision (www.gov.uk).
Assurance
Limited independent assurance is required (finance.ec.europa.eu).
No general independent assurance requirement under current FCA TCFD-aligned listed-company rules (www.fca.org.uk).
Value-chain data
Included where material. The simplified rules limit information an in-scope company can require from value-chain partners with 1,000 employees or fewer (finance.ec.europa.eu).
Relevant where needed to explain material climate risks, opportunities and emissions.
Related legislation
CSDDD, ESPR, PPWR, EUDR and the EU Taxonomy may also be relevant, each under its own scope rules.
SECR and other UK requirements may also apply. UK companies selling into the EU can separately be affected by EU product laws.
Opportunities: In addition to risks, sustainability trends present opportunities to enhance enterprise value through a brand’s licensing business: Sustainable innovation: Expanding licensing into circular and low-carbon product categories. Premium positioning: Building brand equity through ESG-aligned collaborations (e.g. sustainable fashion, reduced impact packaged consumer goods, marketing through digital product passport (DPP) technology. Market access: Partnering with retailers prioritising sustainable product lines. Long-term resilience: Embedding sustainability safeguards into licensing agreements reduces future royalty volatility. Premium positioning is becoming even more important in the present day; with an increasingly conscious market, customers can pick and choose which products to buy based on a company’s environmental impact. With more environmental reporting becoming mandatory and publicly accessible, making sure you are in line with guidelines (reducing environmental impact) can determine whether consumers purchase your product or not. 11
Products of Change | Legislation Lookbook
POC Guidance for calculating GHG Emissions for brand licensing Throughout 2024, POC collaborated with 33 brand owners to create a standard for greenhouse-gas reporting across licensed businesses. This framework will help the global industry align on the data required for collection and disclosure, ensuring consistent and comparable reporting. The draft standard has already been reviewed by the World Resources Institute, which oversees the Greenhouse Gas Protocol, and is now under consideration by the International Standards Board. Rather than a brand owner reporting on the financial value of their licensed product and attributing a carbon metric, which over time as impact reduces but business increases would not showcase an emissions reduction, we are proposing that a brand owner reports on volume of physical produced product, the year of production, and attribute a carbon metric to the volume versus the royalty revenue. Licensor reports emissions related to physical products produced. And the year the emission from production occurred.
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*Pending approval from the International Standards Board via the World Resource Institute.
Licensed manufacturer Outside of the above reporting structures, licensed manufacturers now face some of the heaviest regulatory pressure under the EU Green Deal, with sweeping requirements spanning product design, packaging, supply-chain transparency, and end-of-life responsibility. From increased Extended Producer Responsibility (EPR) fees to digital product passport (DPP) mandates and evolving ESG reporting obligations, compliance is no longer optional – it’s a core business imperative. As discussed earlier, though a brand owner might not be responsible for these ‘producer taxes’, they might require data for their ESG reporting. Retailers, too, are under mounting pressure: even when they do not produce the goods or pay the associated taxes (such as EPR fees), they may still be required to report the total volume and types of materials sold through their stores. This creates a critical need for seamless data sharing between manufacturers, brand owners, and retailers to ensure compliance across the entire value chain. POC’s key advice is to start collecting detailed material data for every product in a single, centralised system. This early action gives you a clear view of the materials and volumes moving through your supply chain and enables you to track and reduce environmental impact. Building that visibility now will make it far easier to meet upcoming reporting requirements, share accurate data with brand owners and retailers, and demonstrate compliance across the entire value chain. 13
Products of Change | Legislation Lookbook
EU Green Deal European Deforestation Regulation (EUDR) Requires traceability and due diligence for commodities such as palm oil, coffee, cocoa, leather, timber, rubber, soy.
Green Claims Directive Removes Greenwashing
Creates transparency and mapping of impact.
Business model innovation
Right-to-Repair initiatives Forces consumer-goods brands to provide parts, manuals, and design products for easy repair.
Extended Producer Responsibility (EPR) Producers pay directly for disposal of their products.
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Eco-design for Sustainable Product Regulations (ESPR) Sets design requirements for durability, reparability and energy/resource efficiency; enables the Digital Product Passport (DPP).
ESPR (Digital Product Passport) Informs and empowers consumers.
Key legislation EUDR The EU has delayed its Deforestation Regulation (EUDR) deadline until 30 December 2026 for medium and large businesses, and 30 June 2027 for most smaller businesses, removed certain products from scope, and simplified reporting so that the business first placing covered goods on the EU market carries out due diligence, while businesses further along the supply chain keep the required traceability records. However, businesses first importing covered goods into the EU must still check that they are deforestation-free and legally produced and submit a due diligence statement, while the first buyer must keep the statement’s reference number and businesses further along the supply chain must keep records of their suppliers and buyers.
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Products of Change | Legislation Lookbook
Useful links for EUDR UK Environmental Act 2021 •
From the British Agriculture Bureau: “The European Commission has notified the UK Government that the regulation will be applied in Northern Ireland under the Northern Ireland Protocol” (britishagriculturebureau.co.uk). This implies that under the Protocol, EUDR will (or is intended to) apply in NI.
•
From the Trade Development UK (TDUK): NI companies should begin preparing for EUDR compliance (e.g. due diligence for relevant products, submitting statements via the EU’s TRACES system), even though formal confirmation is pending (Timber Development UK).
•
From the UK Agriculture & Horticulture / AIC FAQ: “There is no doubt that whilst EUDR will not be implemented in Great Britain (it will apply in Northern Ireland)” (agindustries.org.uk).
For UK companies who need to register to the EU’s Trace system, an EORI number is needed for the registration and is managed by the local customs. You can apply for the EORI number here: https://www.gov.uk/eori (EUDR – Regulation (EU) 2023/1115)
Green Claims Outside of the Empowering Consumers for the Green Transition Directive (ECGT), within the EU (the Greenwashing Directive) which came into force from September 2026, and the UK consumer protection law and the CMA’s Green Claims Code which bans misleading claims and requires evidence, governments have cracked-down on green claims and require evidence based claims, banning products and fining companies significantly that do not comply. This area will increase in complexity over the next three years, this affects all products and brands. And you will see similar legislation rolling out over the coming months elsewhere. 16
ESPR EU – Eco-design for Sustainable Products Regulation (ESPR) The regulation reaches far beyond product design and pushes responsibility across the entire lifecycle to: Design out waste: Products must be conceived for durability, reuse, repair, and recyclability – minimising waste from the start and tackling issues like dead stock. End-of-life financing: Producers are financially responsible for the systems that enable products to be collected, reused, or recycled at end-of-life moving into EPR (Extended Producer Responsibility). As of 19 July 2026 it is banned to destroy unsold clothes and shoes. However, some products can be destroyed for safety, and if a brand requests a product be destroyed, the reporting body has to comply. Full supply-chain transparency: Through Digital Product Passports (DPPs) which will capture and share detailed information on materials, repairability, and environmental impact. Registry is now in operation since 20 July 2026. In 2027 there are plans to make DPP mandatory for certain types of batteries (e.g. electric vehicles and industrial batteries). A digital carrier of information, the DPP will follow products and even the raw commodities they contain – such as wood, palm oil, or other high-risk inputs – ensuring traceability back to origin. For licensed manufacturers, this means integrating circular design, robust data systems, and transparent sourcing into every contract and production process, while budgeting for the ongoing costs (or mitigating through design) of end-of-life management. 17
Products of Change | Legislation Lookbook
DPP working plan The first working plan sets our priority product categories within this timeline: 2026
Iron and steel
2026-2029 Energy related products 2027
Textiles, tyres, and aluminium
2028
Furniture
2029
Mattresses and ICT products
Although the DPP is part of the EU ESPR, they apply to any economic operator placing products within the scope of relevant EU legislation. For example, when being sold on the EU market – manufactured domestically or imported.
For a Global update please see below: Market
Position as of September 2026
EU
The clearest route to mandatory passports: specified batteries need a DPP from 18 February 2027, with product requirements rolling out by sector (European Commission).
China
Developing national DPP standards and sector applications, with a strong focus on traceability and export readiness; a general mandatory requirement has not been established as yet (samr.gov.cn).
UK
Exploring Digital Product Records, its preferred term. Great Britain has not decided on a domestic policy; relevant EU DPP rules will apply in Northern Ireland under the Windsor Framework (gov.uk).
Japan
Developing battery passport and automotive supplychain data systems, including work on sharing battery information with European systems (meti.go.jp).
The key distinction is that China and Japan are building the data infrastructure, while the EU is setting the most concrete market-access deadlines. A product identity system designed for EU compliance could therefore also support traceability, safety information, repair and resale across markets, provided its data can be shared in the formats each market adopts. This is all still being discussed, but a digital carrier of information is not going away; how the markets manage the transference of data, and alignment of data is all being worked through. 18
EPR – Extended Producer Responsibility (UK) There are over 400 live global EPR schemes; they draw from previous producer responsibility systems like the ‘Green Dot’ in Europe and PRN’s in the UK, and ladder up to the UN’s 17 Sustainable Development Goals. The principle is quite simple: the responsibility to pay for the management of packaging waste is put on those who have produced it, i.e. the producer pays. How it’s managed is quite different from country to country and the legal, legislative, and compliance requirements are evolving and changing weekly. There are, however, underlying principles that work across all current and expected packaging EPR systems when it comes to designing packaging. The UK implemented updates to its Extended Producer Responsibility (EPR) regulations for packaging in 2026. These changes aim to ensure that producers cover the full costs of managing the waste from their packaging, thereby encouraging more sustainable practices. Key developments include: In 2025 and 2026, producers have paid/will pay flat base fees per tonne of material, based on average handling and recycling costs – not based on recyclability – paying as much for glass as for plastic for example. During 2026 to 2027, fees will be adjusted and based on recyclability – RAG (red/amber/green) rating system. Modulation will be implemented – the more recyclable your product the less you pay according to the Recyclability Assessment Methodology (RAM). This uses a RAG rating scheme; red = least recyclable, amber = neutral, green = most recyclable. Green gets a discount, amber pays the baseline, red pays more based on modulation (this modulation factor increases each year to increase the financial consequences). The annual modulation factors agreed upon for the next three years for the UK: 2026-2027 = 1.2 2027 to 2028 = 1.6 2028- 2029 = 2.0 19
Products of Change | Legislation Lookbook
How the modulation factor works:
Material
June 2025 base fee
Green fee (in £ per tonne)
Amber fee in £ per tonne)
Red fee (in £ per tonne)
Aluminium
266
245
270
325
Fibre-based composite
461
475
525
630
Glass
192
185
205
245
Paper and board
196
190
210
250
Plastic
423
415
455
545
Steel
259
260
290
345
Wood
280
410
450
540
Other
259
205
225
270
UK – you are in scope if: Turnover over £1 million
£2m+ turnover
AND over 25 tonnes packaging handled/year
50+ tonnes packaging
You must report on: Materials (plastic, paper, etc.) Weight (kg) Packaging type (primary, secondary, tertiary) Household vs non-household EPR fees based on: Volume of packaging Recyclability Note: Poorly designed packaging = higher cost
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Large producer (key group)
Must: Report data every six months Pay EPR fees Cover full waste costs Labelling requirements (WAS) from April 2026 (extended up to 18 months). Packaging must include: “Recycle” / “Do not recycle” Within the UK, many use Valpack to report their data, and the PackUK website is where all updates can be found.
EPR – Extended Producer Responsibility (EU) EPR is a core component of the European Union’s broader Circular Economy Action Plan (CEAP), which aims to reduce waste and enhance product sustainability. The European Union’s legal framework on EPR is primarily governed by directives, such as: Waste Framework Directive (2008/98/EC): Establishes minimum requirements for EPR schemes across member states, including financial responsibility for producers. Packaging and Packaging Waste Directive (94/62/EC): Regulates packaging waste and includes EPR measures for packaging producers. Has applied generally since 12 August 2026, with the goal of making all packaging recyclable by 2030. Directive on Waste Electrical and Electronic Equipment (WEEE) (2012/19/EU): Establishes EPR for producers of electrical and electronic equipment. Single-Use Plastics Directive (2019/904): Implements EPR obligations for producers of certain plastic products, such as food containers and plastic bags. As of 30 June 2026, new chemical methods have been added to the legislation for recycling plastic bottles. Under the Green Deal, the EU aims to update EPR schemes and tighten obligations in areas such as product labelling, reuse and recyclability standards, and promoting eco-design. Licensed manufacturers are responsible for reporting EPR (if they produce and sell product to retailer).
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Products of Change | Legislation Lookbook
EPR comparison ASPECT
EU EPR (PPWR) legislation
UK pEPR (and RAM) legislation
Governance
EU-wide regulations through directives (e.g. WEEE, packaging, single-use plastics).
Post-Brexit, UK-specific rules under the Environment Act 2021.
Primary focus
Circular Economy Action Plan (wider scope: packaging, vehicles, WEEE).
Initially more focused on packaging waste, now shifting to reducing hard to break down recycling, in order to move towards a circular economy.
Cost responsibility
Shared responsibility, eco-modulated fees.
Full cost recovery for packaging, covering collection, recycling, and disposal.
Specific tax measures
Each member state has its own plastic tax, whereas operational costs are down to extended producer responsibility and PPWR.
Plastic Packaging Tax for packaging with less than 30% recycled plastic.
Eco-design standards
Focus on eco-design, reuse, and recyclability.
Similar eco-design requirements but evolving through national legislation.
Business level
UK packaging EPR
EU packaging EPR under the PPWR
Below the UK threshold
Generally outside the UK, pEPR reports if annual turnover is £1 million or less, or the business supplies 25 tonnes or less of packaging.
There is no equivalent EU-wide turnover or tonnage exemption from producer registration. Check the rules in each member state where the business first supplies packaging or packaged goods.
UK small producer
Turnover over £1 million and more than 25 tonnes of packaging, without meeting both large-producer thresholds: must register and report, but does not pay UK household packaging waste disposal fees.
The PPWR provides simplified annual reporting for producers supplying less than 10 tonnes in a member state; this is not a blanket exemption from registration or EPR obligations.
UK large producer
Turnover over £2 million and more than 50 tonnes of packaging: must register, report more detailed data and, where applicable, pay household packaging disposal fees and meet recycling obligations.
Obligations are determined market by market, rather than by the UK’s £2 million/50-tonne test.
The US has no single national packaging EPR framework. Currently seven states (California, Colorado, Maine, Maryland, Minnesota, Oregon and Washington) have passed their own laws, with different requirements and approaches to assessing recyclability against their collection and recycling systems. POC has an EPR working group with our global toy brands. For further information please do contact the POC team.
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Legislation will continue to evolve over the coming years, but there is one step every business can take now: start collecting your data. Work with your supply chain to understand the type, volume and weight of the materials in the products and packaging you buy and sell. That knowledge will help you prepare for new requirements and show where you can reduce waste and environmental impact. We are already seeing businesses save money by simplifying packaging and using materials more efficiently, then reinvesting those savings in lower-impact solutions. At Products of Change, we will continue to share these examples and bring our community together to learn from one another as the landscape changes. Join the POC community and continue the conversation at our annual conference: www.productsofchange.com
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