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Packaging compliance monitoring report 2025

Under The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, we have a statutory duty to publish an annual report setting out our packaging producer responsibility compliance monitoring and enforcement activities. 

Summary

SEPA has a duty to monitor compliance of businesses in Scotland that have obligations including Scottish based producers directly registered with SEPA and any UK producers registered with SEPA approved compliance schemes, as well as Scottish reprocessors and exporters.

Details of our key duties can be found in our 2026 monitoring plan.

Our 2025 regulatory activity involved the following key duties:

• Processing registration of Scottish based producers registering directly with SEPA, as well as registration of compliance schemes and their members.
• Processing registration and accreditation of reprocessors and exporters based in Scotland.
• Assessment of reports submitted by the above to SEPA which included data analysis as well as desk based and physical audits depending on our risk profiling.

Throughout the year we continuously worked with our obligated businesses to ensure compliance by providing timeous advice and guidance. Where SEPA encountered non-compliance, we made sure that our enforcement action was proportionate and in line with our published enforcement policy. 

Monitoring and enforcement activities in 2025

Registered producers and compliance schemes

We assessed all our 48 large direct registrants and assessed 394 (approximately 25%) members of SEPA approved compliance schemes as part of processing applications for registrations.

We reviewed and validated data on packaging placed on the UK market by all our 48 large direct registrants and 615 large producers as a representative sample of data from members of our compliance schemes. Our main aim objective for this exercise was to ensure the data was as accurate as reasonably possible.

We routinely checked for significant variances between reporting periods, focusing on reported tonnages per material, consistency of reported packaging material types versus information provided to us at registration stage. We challenged and sought for an explanation of any outlying variations, including the consistency of interpretation and reporting of household against non-household packaging.

This resulted in 34 resubmissions from 19 direct registrants and 442 resubmissions from members of our 3 compliance schemes to correct the errors identified during the data checks. 275 of these resubmissions incurred a chargeable fee.

Key information from our 2025 activities includes the following:

• 17 producer site audits.
• 615 compliance scheme membership data assessments.  
• 99 data assessments on large producers directly registered with SEPA.
• All 48 Direct Registrants met their recycling targets.
• All our 3 approved compliance schemes met their recycling obligations and submitted satisfactory certification of compliance for the 2025 compliance period.
• 76 members of compliance schemes, 10 large direct registrants and 6 small direct registrants registered late in 2025.

Since our resource and 2025 compliance monitoring work for the 3 compliance schemes concentrated on desktop monitoring and data assessments, we plan to carry out physical audits in 2026. 

Producer enforcement

Although all our large direct registrants complied with their recycling obligations, 7 of them failed to submit a mandatory certificate of compliance. As result SEPA followed up in writing with these producers to advise of the non-compliance and ensure compliance moving forward.
We also accepted 3 Enforcement Undertakings during 2025 totalling £290,659 from companies who had not registered to comply with the regulations in previous years.

Reprocessors and exporters

Scottish reprocessors and exporters have a mandatory requirement to register with SEPA if, in the course of their business, they are receiving packaging waste for reprocessing or exporting it for recycling outside the UK.

On top of processing these registrations for the 2026 compliance period, SEPA also assessed applications from registered operators who opted to be accredited so they could issue evidence of recycling or export for recycling.

Key compliance monitoring activities for reprocessors and exporters included: 

• Ensuring that accredited operators continued to meet conditions of their accreditation.
• Assessing reports submitted by operators on the amount of packaging waste they have managed including the review of and adherence to their operation’s sampling and inspection plan.
• Checking and verifying that exporters are exporting to approved overseas sites and are also complying with International Waste Shipment regulations. 
• Assessing that evidence issued by accredited operators is in line with the conditions of accreditation including verification via desktop and physical site audits

In 2025, we assessed the compliance of 20 reprocessors and 5 exporters which involved assessment of a total of 125 different data reports throughout the year from these regulated organisations. This resulted in 1 resubmission from a reprocessor.

We also undertook 3 physical site audits based on our internal risk profiling.

There was no enforcement action taken against our accredited reprocessors and exporters.

Other work

Throughout 2025, SEPA continued working collaboratively with the rest of the UK regulators (The Environment Agency, Natural Resources Wales, and Northern Ireland Environment Agency) to ensure consistency in our regulatory and compliance monitoring approaches as well as in the development of guidance and interpretation including decisions around development of regulatory position statements. Our collaboration efforts included, feeding into the development of the government guidance, Pack UK’s recyclability assessment methodology (RAM) guidance and the regulators’ agreed positions and technical interpretations.

We have also been supporting the Scottish Government, DEFRA and the other devolved governments in the development and implementation of the new requirements and subsequent amendments to the packaging producer responsibility statutory instrument.