As the UK shifts focus from mandatory to voluntary recycling labels, Jude Allan, Interim Managing Director of OPRL, emphasises the critical role these labels will play in guiding consumers toward sustainable choices.

After years of delays, debates, and adjustments, the UK government has abandoned its plan to introduce mandatory recycling labels on packaging by April 2027. These labels were set to be a cornerstone of the Extended Producer Responsibility for packaging (pEPR) scheme, which seeks to make producers financially accountable for the entire lifecycle of packaging waste. The goal was simple: encourage companies to use more recyclable materials and reduce packaging waste through clear, consistent consumer labelling. However, due to ongoing considerations about post-Brexit relations with the EU—specifically the importance of aligning with European recycling regulations under the Windsor Framework—the plan has been paused for now. However due to issues regarding alignment with the EU, the requirement for mandatory labelling has been removed from the first iteration of pEPR.

This decision comes as a surprise, as the government has been moving forward with the labelling requirements since April 2023. The labels were considered essential in helping consumers make informed recycling choices, and many industry experts viewed the mandatory system as a critical step in increasing recycling rates across the UK. Yet, in a surprise move, Defra (Department for Environment, Food & Rural Affairs) announced that mandatory labelling would not be a part of the initial pEPR regulations, leaving businesses to continue using voluntary labelling systems like the On-Pack Recycling Label (OPRL), which had already seen widespread adoption.

At the Packaging Innovations and Empack event in February 2025, we are set to witness a crucial moment for the packaging industry as it navigates new challenges and opportunities in sustainability and recycling. At this pivotal time, one of the key voices will be Jude Allan, the Interim Managing Director of OPRL, who will share valuable insights into the future of packaging labelling and recycling.

Allan will discuss the recent developments, including Defra’s announcement that mandatory labelling will not be part of the first stages of pEPR. Although this decision represents a slight setback, it was made to avoid unnecessary costs and trade frictions with EU reforms, she is keen to emphasise the importance of not losing momentum.

“Taking mandatory labelling out of the first iteration of pEPR— in order to make pEPR go ahead, that’s the thing,” reiterated Allan. “It’s not that it’s being completely removed. You could say that as we're taking mandatory labelling out because we can’t get it sorted in the time available, that suggests that it’s unimportant. But that’s so not the case. It is still important; however, it’s more critical to ensure that we have pEPR than to let it be derailed by one issue, whatever that issue. In this instance, the labelling happens to be the factor that could have derailed it, so it makes sense for it to be removed. But that’s not deprioritising it.

“For OPRL, our voluntary scheme, we’ve been working for 15 years to communicate with consumers so they know what to do with their packaging after removing the product. They need to clearly decide whether they can recycle it or not, enabling them to do the right thing and set their packaging off on its recycling journey. We have been working toward mandatory labelling in line with the pEPR plans and legislation. This is where the change may come in. For us, that’s a significant challenge as a business ‘We’ve been working toward this situation, and actually it will be different to what we were expecting.’ The label may not simply be the swoosh with ‘recycle’ or ‘do not recycle.’ If we harmonise with Europe more, that could result in a change to the appearance of the label.

“What we’ve been doing is encouraging consumers to engage with recycling. pEPR is all about driving up recycling rates and ensuring that we have materials flowing through the system. This way, the value of the recycling that comes out the other end increases because the quality of the material going in is higher.

“In some ways, we’ve seen this in the communication that has come through since the announcement was made. The voluntary scheme is still essential because we really need labelling to assist pEPR to succeed.”

A critical aspect of improving recycling rates hinges on clear guidance for consumers; this is where labelling plays a vital role. Without clear instructions, recyclable materials risk ending up in the wrong bin, and contamination can disrupt the recycling process. However, the challenge isn’t just about placing labels on packaging—it's about assessing recyclability thoroughly and responsibly.

The Recyclability Assessment Methodology (RAM) will push every business to evaluate their packaging’s recyclability, and this assessment will shape not only the labels but also the modulated fees tied to recycling under the Extended Producer Responsibility framework. Even though labelling may no longer be mandatory in the early stages, it remains a crucial output from this process.

“Decisions about packaging are incredibly complex,” added Allan. “Packaging is essential to our modern lives, but it is also challenging and nuanced. When you start having conversations with people who don’t work in packaging, you can see their eyes glaze over, or their brains start to struggle with the complexity. They just want to know what to do with the packaging: Do I put it in the bin or in the recycling? It’s up to us, and the brand owners, to provide that information.

“We help many of our members navigate these complicated decisions. One of the things we have been doing, in collaboration with Defra and the consultants working on the RAM, is ensuring that their methodology aligns closely with what OPRL has been doing. This has become an industry standard, and the decisions are evidence-based. They are independent and material-agnostic, among other things.

“It’s a really complementary effort; the industry is keen for the base to be what OPRL does because that’s what they know and trust. It’s also crucial for consumers that we don’t enter a situation where people can put whatever they like on their packaging, as this would only confuse them and negatively impact recycling rates in the UK. Clarity in communication must be the best way to achieve this, giving people a reason to believe in the system.”

Without mandatory labels, there is a fear that confusion will persist over what can and cannot be recycled, leading to contamination in recycling streams or, worse, recyclable materials being sent to landfills. This comes at a time when the government is trying to push producers toward more sustainable packaging through the pEPR scheme, which includes modulated fees—higher charges for companies that use materials with a higher environmental impact, and lower charges for materials that can offer additional value through reuse or recycling.

Additionally, the lack of clarity over how pEPR will now address packaging labelling has left industry insiders with unanswered questions. The scrapping of the mandatory labels is seen as a sign of the Labour government's "pragmatic" approach to balancing environmental goals with economic pressures on businesses. Still, critics worry that this pragmatic stance could weaken the overall impact of the pEPR scheme. While the move may prevent a last-minute scramble for labelling compliance, it also raises concerns that it will slow down progress in improving recycling infrastructure and consumer habits.

“Mandatory measures are not off the table; they are coming because they are necessary,” said Allan. “The challenge is that we don’t know exactly when that will happen due to the issues that have come up. However, in the absence of an agreement on what the mandatory requirements will be, the voluntary scheme becomes even more important. As pEPR starts, we need to ensure that people know what to do, and to me, that was a really encouraging sign.

“All those decisions are on a knife edge; we have to figure out how to make a difference without making it ridiculously expensive for brands. If they have to pay for all the packaging they put on the market, and it isn’t getting recycled, the fees they pay will be high with no benefit for anyone. So, we do need to play our part.

“Voluntary labelling in the interim will be really important, along with the messaging. On the B2B side, it’s crucial to communicate with members and those who might think they can just delay action until we have clarity on the mandatory requirements. They really need to start preparing and thinking it through. Even though we don’t yet know what that label will look like, it might still resemble the label we currently have. Regardless, it will still take up some space on their packaging. If they haven’t begun to consider where it will go and how it will work, they will find themselves scrambling to make changes when the time comes. So, progressing with the voluntary label now gives you all sorts of advantages, including preparation for the future.”

With so much uncertainty surrounding packaging regulations and sustainability requirements, Packaging Innovations 2025 comes at a crucial moment, offering much-needed clarity as the industry prepares to fully engage with the pEPR framework. As the reality of pEPR begins to take hold, the event provides a key platform for businesses to regroup, share insights, and find direction as they navigate this new regulatory landscape.

Packaging has shifted from being a behind-the-scenes component of product delivery to a major focus in the sustainability conversation. Consumers and regulators alike are now closely scrutinising how businesses manage their packaging, with clear labelling and sustainable design choices becoming essential tools for demonstrating environmental responsibility. Packaging is often the first point of contact for consumers when it comes to a brand's sustainability efforts, and expectations around recyclable materials, the reduction of single-use plastics, and transparent labelling have never been higher.

“What’s next for labelling? If we now have pEPR, which we hope will be in place by February next year, what does that mean for labelling? What do we need to do? How can we keep everyone engaged?” she said. “That’s probably what I would want to discuss at the show.

“Timing is critical. People will have just realised, ‘Oh, okay, this EPR thing we’ve been talking about for the past five years is finally upon us.’ So, what does that mean for labelling? Is it still going to happen? Why do we need to do it? What is it likely to look like? What does harmonisation mean? Will we harmonise, or will we continue to do our own thing?

As Packaging Innovations 2025 approaches, the event comes at a critical moment for the packaging industry. With the legislative agenda around packaging waste, including pEPR, still in flux, businesses are facing significant uncertainty about how best to prepare for the coming changes. Navigating the evolving requirements for sustainability, recyclability, and labelling has become increasingly complex, making this event an essential platform for industry leaders to gather, share insights, and plan for the future.

For Jude Allan, Interim Managing Director of OPRL, determining a clear focus for her talk has been particularly challenging due to the ever-shifting regulatory landscape. The ongoing changes to waste legislation make it difficult to predict exactly what the requirements will be, but the need for businesses to stay informed and engaged is more important than ever. As the industry adapts to new demands, Packaging Innovations 2025 offers a timely opportunity to provide much-needed clarity and guidance.