SUSTAINABILITY / Analysis

UK Packaging EPR: Who Pays, Year 2 Fees and How to Cut the Bill

climaRevolt
climaRevolt ExpertsWritten and checked by our specialists · Monday, October 26, 2026
6 min read
UK Packaging EPR: Who Pays, Year 2 Fees and How to Cut the Bill

In brief

  • UK packaging Extended Producer Responsibility (EPR) makes businesses that supply packaging pay the cost of collecting and recycling household packaging waste.
  • Large producers, with turnover over £2 million and more than 50 tonnes of packaging a year, report data every six months and pay fees. Small producers, with turnover over £1 million and more than 25 tonnes, report once a year and do not pay fees.
  • From year 2 (April 2026 to March 2027), fees vary by how recyclable the packaging is: red-rated packaging pays more, green-rated pays less.
  • Year 2 fees are based on packaging supplied in calendar year 2025, with invoices from October 2026.

Packaging EPR is now a real cost for UK brands and retailers, and from year 2 the cost depends on packaging design. This guide explains who is affected, what they must do, and how to cut the bill.

Are you a producer?

You may be a producer if you pack or fill goods into packaging, import packaged goods, sell packaging, own a brand, or hire out reusable packaging. The size tests decide what you must do.

Packaging EPR size tests
TypeTestWhat you must do
Large producerTurnover over £2 million and more than 50 tonnes of packaging supplied a yearRegister, report data every six months, pay waste management fees, meet recycling obligations
Small producerTurnover over £1 million and more than 25 tonnes (and not large)Register and report data once a year; no fees
Below bothTurnover £1 million or less, or 25 tonnes or lessNo EPR obligations

Groups are assessed together, and the tests use your most recent annual accounts. The government’s guidance has detailed rules on who counts as the producer for each type of packaging.

How the fees work from year 2

Large producers pay fees for household packaging, based on the weight and material they supplied. From year 2, PackUK, the scheme administrator, adjusts the fee by a recyclability rating: packaging rated red (hard to recycle) pays more than the amber base rate, and green (widely recyclable) pays less. Illustrative figures published for year 2 showed red-rated packaging paying around 20% more than amber. Check PackUK’s confirmed fees for your materials.

From year 2, packaging design is a line on your invoice. The cheapest tonne is the one you do not supply; the next cheapest is the one that is easy to recycle.

How to reduce your EPR cost

Practical ways to lower packaging EPR fees
ActionEffect
Measure accuratelyWeigh packaging by component and material; estimates often overstate weight
Remove unnecessary packagingLess weight means lower fees
Move to mono-materialsSingle-material packaging is more likely to be rated green
Avoid problem componentsMixed laminates, black plastics and some coatings tend to rate red
Switch to reusables for B2BFees target household packaging; reusable transit packaging can lower your exposure

EPR data is also useful for your carbon footprint: packaging is part of Scope 3 category 1 (purchased goods) and category 12 (end-of-life treatment). See Scope 3 explained. If you sell into the EU as well, note that the EU Packaging and Packaging Waste Regulation sets separate rules.

Frequently asked questions

Who pays packaging EPR fees in the UK?

Large producers: businesses with turnover over £2 million that supply more than 50 tonnes of packaging a year.

Do small producers pay EPR fees?

No. Small producers (turnover over £1 million and more than 25 tonnes, but not large) register and report once a year, but do not pay fees.

What is the RAM rating?

The recyclability assessment that rates packaging red, amber or green. From year 2, it changes the fee: red pays more, green pays less.

When are year 2 EPR fees invoiced?

Year 2 runs from April 2026 to March 2027, based on packaging supplied in 2025, with invoices from October 2026.

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