Consultancy guide · Circular economy
Circular economy consultancy: the work, the rules, and how to choose
Circular economy consultancy helps a business keep materials in use for longer — and in the UK, much of the pressure to do it now comes from law: packaging extended producer responsibility, the Plastic Packaging Tax and deposit return.
There is still no Circular Economy Act for the UK or England, so the rules are scattered across several instruments with different owners.
This guide explains what circular economy consulting covers, which rules sit behind it, and what to ask circular economy consultants before you appoint one.
Circular economy consulting
What the work actually covers
A description of the field, not a service menu: these are the areas a circular economy consultancy typically works in.
Material and waste flows
Mapping what comes in, what leaves as product and what leaves as waste — the baseline for everything else.
- Material flow and waste audits
- Packaging data for EPR reporting
- Industrial symbiosis: one site’s waste as another’s input
Product and packaging design
Designing for reuse, repair, disassembly and recycling, and choosing materials with that in mind.
- Recyclability against PackUK’s assessment methodology
- Recycled content for the Plastic Packaging Tax
- Life cycle assessment of design options
Business models
Moving revenue from selling more units to keeping units in use.
- Rental, leasing and product-as-a-service
- Refill, reuse and take-back schemes
- Refurbishment and resale
Measurement and reporting
Turning circularity into evidence a board, an investor or a regulator can use.
- Circularity metrics and targets
- Scope 3 categories linked to materials and waste
- Disclosures under UK SRS, CDP or EU rules
The strongest circular economy consultants start with the data, because a redesign or a new model is only as good as the flow map behind it.
In the UK, the compliance work under packaging EPR and the Plastic Packaging Tax is often the first paid job, and the strategic work follows from it.
Our sister site has a fuller circular economy consultancy guide covering methodology and sector detail.
The UK rules
No Circular Economy Act — but plenty of law
Circular economy rules in the UK are spread across packaging, tax, deposit and waste instruments, each with its own threshold and owner.
| Rule | Who it reaches | What it requires | Status |
|---|---|---|---|
| Packaging EPR | Large producers: turnover over £2m and over 50t of packaging. Small: over £1m and over 25t | Data reporting; for large producers supplying household packaging, disposal fees; for large producers, recycling obligations met with PRNs and PERNs | In force |
| Plastic Packaging Tax | Manufacturers and importers of 10 tonnes or more of plastic packaging a year | £228.82 a tonne on components with under 30% recycled plastic | In force; rules change 1 April 2027 |
| Deposit return | Producers and retailers of in-scope drinks containers | A deposit on PET, aluminium and steel containers of 150 ml to 3 litres; glass in Wales only | Launches 1 October 2027 |
| Simpler Recycling | Businesses and households in England | Separate collection of recyclable waste streams | In force; micro-firms exempt until 31 March 2027 |
| Circular Economy (Scotland) Act 2024 | Scotland | A circular economy strategy and targets | Core provisions in force 1 August 2025 |
Packaging EPR’s tiers are AND tests: a business with £3 million turnover that supplied 40 tonnes is a small producer, not a large one.
Turnover comes from the last filed accounts ending before 7 April in the previous year; tonnage from two years before.
Packaging EPR and the Plastic Packaging Tax are separate regimes with separate thresholds and regulators.
There is no offset between them: both can bite on the same tonne of plastic.
Packaging EPR in 2026
Packaging EPR: the dates and the traps
Packaging EPR did not replace the old recycling notes: a large producer still meets recycling obligations by buying PRNs and PERNs, on top of any disposal fees.
The obligation for a year is last year’s tonnage multiplied by that year’s target in Schedule 5; for 2026 the plastic target is 57% and the glass target 76%.
Disposal fees fall on large producers that supplied household packaging, and never on sellers; small producers pay neither disposal fees nor PRNs.
Only the 2025/26 base fees are final: PackUK has said it will issue the 2026/27 notice of liability by the end of November 2026, and its illustrative figures are likely to change.
Recyclability for 2026 data is assessed under RAM 1.1; RAM 2027 applies only to packaging supplied in 2027.
Non-glass drinks containers already sit outside disposal fees, ahead of deposit return in October 2027.
- 1 Jan 2026Amendments in force
SI 2025/1369 changes who is a producer and what each pays.
- 1 Apr 2026Plastic Packaging Tax rate rises
£228.82 a tonne.
- 1 Oct 2026Large producer data due
January–June 2026, assessed under RAM 1.1.
- Nov 20262026/27 fees expected
PackUK’s stated target for the notice of liability.
- 1 Apr 2027Plastic tax rules change
Pre-consumer plastic stops counting as recycled.
- 1 Oct 2027Deposit return launches
Sources: SI 2024/1332 reg 35 · PackUK · FA 2026 s.107 · SI 2025/67
Plastic Packaging Tax
The plastic tax changes on 1 April 2027
The tax is charged at £228.82 a tonne under section 45 of the Finance Act 2021, on plastic packaging components whose recycled plastic content is less than 30%.
Registration is required once a business manufactures or imports 10 tonnes of finished plastic packaging components in 12 months, or expects to in the next 30 days.
Two changes take effect on 1 April 2027 under section 107 of the Finance Act 2026.
Pre-consumer plastic will no longer count as recycled plastic, so a component that clears the 30% test today on pre-consumer recyclate can become taxable with nothing about it changed.
And chemically recycled content attributed through a certified mass balance scheme will start to count.
legislation.gov.uk already shows the mass balance words in section 47, with only a footnote; the commencement date is in the 2026 Act.
Policy
Scotland, England and the EU
Scotland is the only UK nation with a circular economy statute: the Circular Economy (Scotland) Act 2024, whose strategy and targets provisions came into force on 1 August 2025 under SSI 2025/170.
In England, the Circular Economy Taskforce, set up in late 2024, is an independent advisory group with no statutory role.
The European Commission’s circular economy strategy aims to double the EU’s circular material use rate to 24% by 2030, from about 12% today.
The Commission describes its Circular Economy Act as due for adoption in 2026; it is a proposal, not law, and it would not apply in the UK.
WRAP sets out its vision for a UK circular economy, and Circle Economy publishes an annual Circularity Gap Report measuring how much of the global economy’s material input is cycled back; both are context, not law.
The England strategy, announced in March 2025 and renamed the Circular Economy Growth Plan, was still described as upcoming by the Environment Agency in July 2026.
In your reporting
Where circularity shows up in a report
| Where | What circularity feeds |
|---|---|
| Scope 3 emissions | Purchased goods and services, waste generated in operations, and end-of-life treatment of sold products are all Scope 3 categories |
| UK SRS S1 | Sustainability-related risks and opportunities generally, including resource dependency |
| ESRS E5 (EU) | Resource use and circular economy, for companies in CSRD scope |
| CDP | Plastics questions, not scored in 2026 |
| SECR | Nothing directly — SECR covers energy and a narrow transport-fuel limb only |
Circular measures are also emission reduction measures, so they belong in a science based target and in the transition narrative of a climate disclosure.
Under the FCA’s final rules in PS26/19, listed companies in scope report against UK SRS on a comply-or-explain basis from 2027, with a two-year relief for non-climate matters such as resource use.
For energy and emissions data, our sister reference site covers SECR in depth.
Circular economy consultants
Questions to ask before you appoint
Which regimes apply to us — packaging EPR, the plastic tax, deposit return, Simpler Recycling — and how do you know?
Will you start from our own material and waste data, and who collects it?
Which recyclability methodology will you use for 2026 data, and for 2027?
How will you evidence recycled content for the Plastic Packaging Tax, before and after April 2027?
How will the work show up in our Scope 3 figures and our sustainability reporting?
Do you earn anything from the materials, equipment or schemes you might recommend?
What does the quote include, and who owns the models and data afterwards?
Can you show published work, rather than client names, that shows your method?
A typical engagement runs from a readiness assessment and flow map, through design of changes and pilots, to scaling what works — but the order matters more than any timetable.
SRS Report is an independent reference, not a consultancy practice; a network of independent specialists exists, and the carbon compliance guide covers choosing help more generally.
Questions or corrections are welcome through the contact page, and you can book a free 15-minute call to talk through what you need.
Frequently asked
Questions people ask
What does a circular economy consultancy do?
Circular economy consultancy helps an organisation keep materials and products in use for longer: mapping material and waste flows, redesigning products for reuse, repair and recycling, developing reuse, refill, rental or resale models, and meeting the UK packaging, plastic tax and waste rules. Good consultants also connect the work to the organisation’s emissions and sustainability reporting.
Is there a UK Circular Economy Act?
No. There is no Circular Economy Act for the UK or for England. Scotland has one, the Circular Economy (Scotland) Act 2024, whose core strategy and targets provisions came into force on 1 August 2025. England’s Circular Economy Growth Plan had still not been published when this page was checked, and the EU’s Circular Economy Act is a proposal due for adoption in 2026.
Which UK laws drive circular economy work?
Mainly packaging extended producer responsibility (SI 2024/1332), which charges large producers disposal fees and sets recycling obligations; the Plastic Packaging Tax on components with less than 30% recycled plastic; the deposit return schemes launching on 1 October 2027; and Simpler Recycling in England.
Who counts as a large producer under packaging EPR?
A business with turnover of more than £2 million that supplied more than 50 tonnes of packaging. A small producer has turnover of more than £1 million and supplied more than 25 tonnes. Both limbs must be met in each tier, and they are measured in different years.
What is the Plastic Packaging Tax rate?
£228.82 per tonne from 1 April 2026, on plastic packaging components containing less than 30% recycled plastic. From 1 April 2027 pre-consumer plastic stops counting as recycled plastic, and a mass balance rule for chemically recycled content takes effect.
How does the circular economy show up in sustainability reporting?
Mostly through Scope 3 emissions — purchased goods, waste and the end-of-life treatment of sold products are all Scope 3 categories — and through resource-use disclosures where a framework asks for them. UK SRS S1 covers sustainability-related risks and opportunities generally, and EU companies in CSRD scope report under ESRS E5 on resource use and circular economy.
How much does circular economy consulting cost?
No public source sets a price for circular economy consulting, and fees vary with scope, product range and data. Ask for a written, itemised quote. The statutory costs around it — packaging EPR fees and the Plastic Packaging Tax — are published by PackUK and HMRC.
Does SRS Report offer circular economy consultancy?
SRS Report is an independent reference, not a consultancy practice. A network of independent specialists exists, and you can book a free 15-minute call to work out what you need first.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.
- legislation.gov.ukSI 2024/1332 — Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024
Packaging EPR, as amended from 1 January 2026.
- legislation.gov.ukSI 2024/1332, regulation 24 — large and small producers
More than £2m and 50 tonnes; more than £1m and 25 tonnes.
- legislation.gov.ukSI 2024/1332, Schedule 5 — recycling targets
Material targets to 2030.
- PackUKPackUK publishes Recyclability Assessment Methodology (RAM) 2027
RAM 1.1 governs 2026 data; RAM 2027 is not retrospective.
- legislation.gov.ukFinance Act 2021, section 45 — Plastic Packaging Tax rate
£228.82 per tonne from 1 April 2026.
- legislation.gov.ukFinance Act 2026, section 107 — commencement
Mass balance and the pre-consumer change from 1 April 2027.
- legislation.gov.ukSI 2025/67 — Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025
In force 1 October 2027; glass out of scope.
- legislation.gov.ukWSI 2026/103 — the Welsh deposit return scheme
Also 1 October 2027, with glass in scope.
- legislation.gov.ukSI 2025/140 — Separation of Waste (England) Regulations 2025
Micro-firms exempt until 31 March 2027.
- legislation.gov.ukCircular Economy (Scotland) Act 2024 (asp 13)
Scotland only.
- legislation.gov.ukSSI 2025/170 — Circular Economy (Scotland) Act commencement No. 2
Strategy and targets provisions in force 1 August 2025.
- GOV.UKCircular Economy Taskforce
An independent, non-statutory advisory group.
- European CommissionCircular economy — DG Environment
The 24% by 2030 goal; the Circular Economy Act due for adoption in 2026.
- GHG ProtocolCorporate Value Chain (Scope 3) Standard
The fifteen Scope 3 categories where material flows show up.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Published 25 February 2026.