COLLECTIONS, PACKAGING AND REFORMS PROGRAMME

Rating: Compared to financial year 24/25 Q4, the NISTA/SRO Delivery Confidence Assessment (DCA) rating at 25/26 Q4 remained at Amber. The programme was also rated Amber in the annual NISTA Review in May 2025. The report concluded that while the CPR programme improved and is broadly feasible (Amber), delivery remained highly complex and time-critical, requiring urgent action on commercial capability, contingency planning, stakeholder engagement, and benefits realisation to mitigate risks and ensure intended outcomes are achieved. All recommendations were actioned withing the given timescale. This rating is primarily due to the following factors: progress continued across legislation, funding and business readiness, with delivery increasingly focused on mobilisation and transition to live operations; however, outcomes remained sensitive to partner readiness, capacity constraints and reliance on digital delivery. For Extended Producer Responsibility for packaging (pEPR), the Amending SI was laid on 3 November and tracked to come into force on 1 January 2026, with Notices of Liabilities issued to producers on 14 October (4,305 invoices totalling £1.465bn) and delivery of some digital functionality pivoted to alternative plans to protect critical delivery. For Deposit Return Scheme (DRS), a Deposit Management Organisation (DMO) candidate for England and Northern Ireland was appointed on 2 May, progressed recruitment and financial modelling, split the IT programme into five phases (phase 1 analysis/design) and launched scheme branding (“Exchange for Change”), while highlighting the need for greater certainty before entering key contractual commitments. For Simpler Recycling Collections (SRC), delivery remained challenged by Local Authority funding and readiness risks (including Spending Review 25 Phase 1 decisions), mitigated through enhanced engagement (including a ‘Change Network’) and infrastructure planning; by Q3 over £258.3m had been paid to LAs for upfront costs and mobilisation continued toward household go live on 31 March 2026. For Digital Waste Tracking (DWT), Alpha was passed on 25 June 2025 (rated Amber), Private Beta commenced (from 16 July subject to approvals) and began testing on 7 November 2025, with Phase 1 legislation and the Impact Assessment progressing and public beta planned for April 2026. Delivery remains dependent on external partners (including Local Authorities, producers and waste management companies) being ready and able to adopt reforms, and continues to be constrained by infrastructure and processing capacity (notably for flexible plastics), supply chain constraints for physical assets (bins/vehicles), variability in local resourcing, and ongoing reliance on digital systems and data outputs across projects. The focus moving into the next quarter is on stabilising live delivery, intensifying readiness and engagement activity, and protecting delivery-critical milestones to prevent slippage and avoid risk escalation.

Schedule: Compared to financial year 24/25-Q4, the project's end-date at 25/26-Q4 increased from 1 May 2028 to 1 June 2028. This is due to aligning with the DRS closure date captured within the milestones.

Cost: The figure differs from the previous year’s annual report as the GRIP was completed using a different methodology. When compared to the previous version of the PBC in December 2024, the project's Whole Life Cost decreased from £19,792m to £13,643m. The reductions are in part due to changes in assumptions for funding allocation for Simpler Recycling since previous projections.

Source: NISTA Major Projects Annual Report 2025-26 (data)

Rating: Compared to financial year 23/24-Q4, the Infrastructure Project Authority's Delivery Confidence Assessment rating at 24/25-Q4 remained at Amber. This is primarily due to the following factors‚ The previous assurance review of the CPR programme (Nov 23) highlighted critical concerns around the timelines for the Packaging Extended Producer Responsibility (pEPR) and Deposit Return Scheme (DRS) projects, particularly due to dependencies on secondary legislation, limited influence over local authorities, gaps in the pEPR commercial strategy, and resourcing challenges. Since then, a strong Programme team has been established, and progress has been made both technically and with stakeholders. However, several key risks remain and require continued focus: underperformance in IT system delivery for pEPR (though not currently affecting immediate milestones), a tight schedule for implementing the second phase of pEPR charging, unresolved issues around a pan-UK DRS agreement, local authority funding and delivery challenges, the need for sustained behaviour change across citizens and industry, and enforcement risks. The current performance of the programme team suggests that these should be capable of resolution, but success will depend on the capability and effectiveness of key private sector partners, particularly scheme management organisations.

Schedule: Compared to financial year 23/24-Q4, the project's end-date at 24/25-Q4 increased from 31/03/2027 to 01/05/2028. This is primarily due to the following factors‚ The Collection & Packaging Reforms Programme continues to make progress towards deliverables with multiple Statutory Instruments laid in Parliament; Digital Waste Tracking are scheduled to lay Phase 1 Statutory Instrument in spring 2026. As a result of the delays in the delivery of Digital Waste Tracking to April 2026, and the Deposit Return Scheme to October 2027, the programme's end date has been increased to 01/05/2028 to accommodate programme closure activities post-delivery of key projects. The programme will continue to review the planned schedule and escalate any decisions required around meeting or changing key milestones via the appropriate escalation routes.

Cost: The project's departmentally agreed Whole Life Cost at 24/25-Q4 (measured in £m) is 1192. This is primarily due to the following factors‚ Whole life cost (WLC) of the Collection & Packaging Reforms Programme aligns to HM Treasury's Green Book governance, and encompasses the total financial commitment required over the entire lifespan of a project. This includes all costs associated with its development, implementation, operation, maintenance, and decommissioning of assets that the project owns e.g. IT. The key components of the Collection & Packaging Reforms Programme WLC include: – Initial Capital Costs. – Expenses related to design, development and procurement. – Operational Costs. – Ongoing expenses such as staffing, utilities, and administration. – Maintenance & Repair Costs. – Costs for upkeep, servicing, and unexpected repairs. – Replacement Costs. – Expenses for renewing or upgrading assets over time. – End-of-Life Costs. – Decommissioning, disposal, or repurposing costs.

Source: NISTA Annual Report 2024-25 (data)

Rating: Compared to financial year 22/23-Q4, the Infrastructure Project Authority's Delivery Confidence Assessment rating at 23/24-Q4 decreased from Red to Amber. This is primarily due to the following factors. The Infrastructure Project Authority's Delivery Confidence Assessment rating at 2324 Q4 has improved to Amber. DEFRA agrees with this rating. Detailed plans are in place to address all of the IPA recommendations within the agreed timeline.

Schedule: Compared to financial year 22/23-Q4, the project's end-date at 23/24-Q4 remained schedule to finish on 2027-03-31. This is primarily due to the following factors. The programme was successfully reset in 2023. With meticulous management of our legislation and delivery, delivery is feasible, though highly challenging. There is limited contingency in CPR plans and key ministerial decisions remain outstanding; a late autumn general election could further impact. In response the team have identified and escalated priority decisions to safeguard key milestones. The programme will continue to review the planned schedule and escalate any decisions required around meeting or changing key milestones via the appropriate escalation routes.

Cost: Exempt under Section 35 of the Freedom of Information Act 2000 (Exempt under Section 35 of the Freedom of Information Act 2000 (Formulation of government policy,etc.))

Source: IPA Annual Report 2023-24 (data)