The Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025: Implications for UK health and safety law and regulatory compliance

The Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025: Implications for UK health and safety law and regulatory compliance

What has changed

The amendment to the Packaging and Packaging Waste Regulations 2024 (S.I. 2024/1332) makes changes to the framework that governs producer responsibilities for packaging waste. The exact modifications are set out in the amending instrument and may affect duties on packaging producers and importers, including how data is collected and reported. Organisations should obtain the full text of the amendment and compare it with the 2024 Regulations to identify precise impacts on their packaging activities.

Why this matters for businesses

Although environmental regulation sits alongside health and safety law, effective regulatory compliance requires a coherent governance approach. The amendment could influence your risk profile by changing reporting timelines, data requirements and the scope of obligations across the packaging supply chain. Non compliance can lead to enforcement action, penalties and reputational risk. Aligning packaging compliance with your health and safety management helps demonstrate robust governance and readiness for both HSE requirements and environmental duties.

What organisations should do next

Take the following steps to safeguard compliance and maintain business continuity:

1. Obtain and review the amending instrument and compare it with the 2024 Regulations to identify exact changes that affect your operations.
2. Map packaging materials and product flows to determine who has duties in your organisation and across your supply chain.
3. Update internal policies and procedures, including data collection, packaging declarations and waste management arrangements.
4. Review supplier and contractor arrangements to embed compliance expectations in procurement and performance management.
5. Update risk assessments and control measures to reflect new obligations and ensure appropriate governance.
6. Consider enhancements to your management system, for example ISO 45001 occupational health and safety management and ensure access to health and safety risk assessments for hazard identification and risk control.
7. Provide training and clear communication to teams involved in packaging and waste management.
8. Establish monitoring, auditing and reporting to demonstrate ongoing compliance and support regulatory assurance.

The breadth of changes means that governance, data quality and supplier oversight are likely to be key focus areas. Integrating the update into an ongoing compliance programme helps ensure legal duties are met and that packaging waste reduction targets align with health and safety management systems.

In summary, timely review and action will help you avoid disruption and ensure responsible packaging practices across your business.