Extended Producer Responsibility - an overview
Background
Food and drink manufacturers fully support the need to reduce the negative environmental impact of packaging and to protect the planet. We have long called for reform of the packaging producer responsibility system to drive improved circular outcomes for packaging, increase transparency and better targeting of funds towards improving recycling infrastructure.
We want to constructively engage with the UK and devolved nations governments to build an efficient and effective world class system that delivers good recycling outcomes for the long term whilst minimising cost to business and to consumers.
The objectives behind packaging Extended Producer Responsibility (pEPR) are to drive further circularity of packaging by reducing unnecessary and difficult to recycle packaging and increasing recycling. It aims to do this by making producers pay the full net disposal costs for the packaging they place on the market.
The learnings from international best practice suggest that adopting a producer leadership model for pEPR represents the most efficient and cost-effective way of achieving these objectives. pEPR is a complex project to be delivered at scale and will place substantial new costs on the UK’s food producers, much of which will get passed on to consumers.
There are also many interlinkages and interdependencies between pEPR and the other parts of the Government’s Collection and Packaging Reforms, namely DRS and consistent collections. A whole systems approach is therefore needed involving correct sequencing, and cross-and inter government working and agreement if we are to achieve the whole system transformation that is needed.
The industry needs assurance that the new system will be as cost efficient and transparent as possible and that it can drive whole system change - from how companies use packaging through to how consumers engage with new recycling systems, as well as how councils manage waste collections and help to drive up recycling rates.
In January 2025, PackUK was formally appointed by Defra as the scheme administrator. PackUK sets fee rates and collects disposal fees from obligated producers.
On 23 March 2026, UK Packaging PRO was appointed as the producer-led body that will assume functions within the pEPR scheme. Its formal appointment commenced on 1 April 2026, with responsibilities being introduced gradually. PackUK continues to oversee the PRO and retains core administrative powers, including final decisions on local-authority payments and producer fees.
The producer leadership model is the successful norm for effective pEPR schemes globally and FDF firmly believes this model is central to the scheme’s successful delivery, including the effective optimisation of costs.
The UK and the devolved nations governments have shown some flexibility by removing proposals to include business waste payments in the overall pEPR policy framework. In England and Northern Ireland the respective governments have decided not to extend EPR payments to cover binned and ground litter until there has been time to assess the impact of a future DRS scheme.
The Scottish Government remains committed that pEPR should cover the full net costs of both binned and ground litter clean-up and disposal. In Wales, the Government consulted between 30 January and 24 April 2026 on options for bringing street-binned and ground-litter packaging waste within pEPR.
Are you in scope?
You must take action to comply if the following apply:
- you’re an individual business, subsidiary or group established in the UK
- you supplied or imported more than 25 tonnes of packaging in the UK in the previous year and your annual worldwide turnover was more than £1 million
- you carry out any of the following activities:
- packaging own-brand products to supply to UK consumers
- using a third party to package and supply own-brand goods to UK consumers
- using unbranded secondary or tertiary packaging to protect goods during transport so they can be supplied to UK consumers
- supplying empty packaging that you manufacture or import to a business that does not meet the large-producer threshold
- importing goods from a brand that does not have a UK presence
- removing packaging from imported goods
- hiring or loaning out reusable packaging to UK third parties
- owning an online marketplace facilitating the sale of packaged goods from outside the UK
- selling filled packaging to an end user, whether a consumer or a business
Producer thresholds
|
Packaging supplied/imported |
£1m or less turnover |
More than £1m to £2m |
More than £2m |
|
25 tonnes or less |
No obligation |
No obligation |
No obligation |
|
More than 25 tonnes to 50 tonnes |
No obligation |
Small producer |
Small producer |
|
More than 50 tonnes |
No obligation |
Small producer |
Large producer |
What you need to do
Small producer
If you are an organisation with either of the below:
- an annual turnover of more than £1 million and you handle more than 25 tonnes but no more than 50 tonnes of packaging within the UK
- an annual turnover of more than £1 million but not more than £2 million and you handle more than 50 tonnes of packaging within the UK
You are obligated to report your packaging data annually but will not be financially obligated to contribute recycling or disposal costs. Specifically, you must:
- register your business through the Report Packaging Data service
- pay a registration fee to the environmental regulator
- have your account verified by an approved person
- submit packaging data for 1 January to 31 December 2026 and register by 1 April 2027
- take steps to record data about all the empty packaging and packaged goods you handle and supply through the UK market
Large producer
If your organisation has an annual turnover of more than £2 million and handles more than 50 tonnes of packaging in the UK, you must:
- register your business through the Report Packaging Data service
- have your account verified by an approved person
- buy PRNs or PERNs to meet your recycling obligations; a compliance scheme can do this on your behalf
- submit data, in kilograms, about empty packaging or packaged goods you handled or supplied through the UK market
- pay a registration fee to the environmental regulator
- pay disposal fees for household packaging, packaging that commonly ends up in public bins and glass household drinks containers
For packaging placed on the market from 1 January to 30 June 2026, submit data by 1 October 2026.
For packaging placed on the market from 1 July to 31 December 2026, submit data by 1 April 2027.
The 2025-26 instalment dates shown in the previous version have now passed. PackUK intends to issue the initial notice of liability for the 2026-27 assessment year by the end of November 2026; producers should follow the payment dates set out in that notice.
What you need to consider
Household and non-household packaging
Disposal fees are payable for household packaging, packaging that commonly ends up in public bins and glass household drinks containers, so it is important to correctly differentiate between household and non-household packaging when reporting data.
Secondary and tertiary packaging must be classed as non-household.
Primary and shipment packaging must be classed as household unless:
- you supply it directly to a business or public institution which is the end user of the packaging, or which supplies goods to an end user with all packaging removed
- you supply it indirectly to a business or public institution, for example via a wholesaler, and the packaging is for a product designed only for business or public-institution use and is not reasonably likely to be disposed of in a household or public bin
- you are an importer and import packaging into the UK which is discarded without being supplied to anyone
You need to be able to show evidence if classing primary or shipment packaging as non-household, and you must keep this evidence for at least seven years.
The existence of a private commercial waste collection does not, by itself, allow primary or shipment packaging to be classed as non-household.
The Government is aware of ongoing concerns that the exemptions from the definition of household packaging are not working as intended, particularly where distribution is via third parties. These concerns include the implications for producer fees given the perceived disconnect between where waste is disposed of and regulatory definitions. We are currently working with Defra, the regulators and other industry bodies to find the right solution for this issue.
We will provide further guidance and updates for members as this work progresses.
Reporting nation data
For any organisation that must act under EPR, you must also submit nation data if you do any of the following:
- supply packaging directly to customers in the UK, where they are the end user of the packaging
- supply empty packaging to UK organisations that are either not legally obligated or are classed as a small producer
- hire or loan out reusable packaging
- own an online marketplace through which organisations based outside the UK sell empty packaging or packaged goods to UK consumers
- import packaged goods into the UK for your own use and discard the packaging
An organisation is not obligated if its annual worldwide turnover is £1 million or less, or if it supplied or imported 25 tonnes or less of packaging in the relevant threshold year.
The underlying nation-data and self-managed organisational waste reporting duties remain in the regulations, but the environmental regulators have issued nation-specific regulatory positions affecting collection and reporting. The current GOV.UK deadlines page links to the positions for England, Scotland, Wales and Northern Ireland; producers should check the statement for the nation in which they are registered before each submission.
Small producers do not report nation-of-sale or self-managed organisational waste data. They report their packaging data annually using the small-producer reporting codes.
Mandatory binary labelling
In the process of finalising the pEPR Regulations in 2024, a decision was taken to remove the provisions relating to the introduction of mandatory labelling pending a review of the provisions developed under the EU Packaging and Packaging Waste Regulation (PPWR) and the scope for alignment, in order to reduce complexity for producers selling into both markets.
Collecting and submitting your packaging data
When collecting data for your submission you must consider:
- individual materials in the packaging you handle and supply
- whether a piece of packaging is primary, secondary, tertiary or shipment packaging
- whether the packaging is likely to become household or non-household waste
- whether the packaging is likely to end up in street bins
- what material types are used in the packaging you handle, including paper/cardboard, glass, aluminium, steel, plastic, wood, fibre-based composites and other materials
All weights must be reported in kilograms.
Since January 2025, large producers have been required to report plastic household and public-binned packaging as either rigid or flexible. This is separate from RAM reporting and applies even if RAM data is not submitted.
Base fees and fee modulation
First-year base fees and year-two illustrative fees
The final base fees used for the first assessment year, 2025-26, are shown below. PackUK's illustrative 2026-27 green, amber and red fees are included for planning purposes.
|
Material |
2025-26 confirmed fee per tonne |
2026-27 illustrative fee per tonne |
|
Aluminium |
£266 |
£245 / £270 / £325 |
|
Fibre-based composite |
£461 |
£475 / £525 / £630 |
|
Glass |
£192 |
£185 / £205 / £245 |
|
Paper and card |
£196 |
£190 / £210 / £250 |
|
Plastic |
£423 |
£415 / £455 / £545 |
|
Steel |
£259 |
£260 / £290 / £345 |
|
Wood |
£280 |
£410 / £450 / £540 |
|
Other |
£259 |
£205 / £225 / £270 |
Within the 2026-27 column, figures are shown as Green / Amber / Red. They are PackUK's December 2025 illustrative estimates, rounded to the nearest £5, and are not confirmed rates; the green discount may change with final reported RAM proportions. PackUK plans to calculate the confirmed year-two fees in November 2026 and issue the initial 2026-27 notice of liability by the end of that month.
Fee modulation and the RAM
From the 2026-27 assessment year, the household packaging waste disposal fee element is modulated based on the recyclability of packaging. Packaging that is harder to recycle attracts higher fees, while packaging that is easier to recycle is subject to lower fees relative to the material base fee, encouraging more recyclable packaging design.
The Recyclability Assessment Methodology (RAM) provides technical guidance for assessing recyclability using a traffic-light grading system: green indicates easy-to-recycle materials, amber indicates materials that present barriers to recycling, while red denotes those that are difficult to recycle. RAM is reviewed annually and updated versions are published ahead of each reporting cycle.
For red-rated packaging, the household packaging waste disposal fee element is multiplied by the modulation factor for that year. Green-rated packaging receives an equal-percentage discount to that element, funded by the additional fees raised from red-rated packaging. Amber-rated material receives no modulation adjustment.
The red-rating modulation factors are 1.2 for 2026-27, 1.6 for 2027-28 and 2.0 for 2028-29.
Use RAM version 1.1 for packaging supplied in the 2026 reporting year. RAM 2027 applies to household packaging supplied during the reporting year from 1 January to 31 December 2027.
The earlier RPS 350 enforcement concession applied only to RAM data for 1 January to 30 June 2025. It does not relax later RAM reporting requirements.
How much will it cost manufacturers?
The financial implications of Extended Producer Responsibility for manufacturers will be substantial, with costs determined primarily by the recyclability of the packaging they place on the market. From 2026-27, red-rated packaging is subject to an increasing modulation factor. By 2028-29, the household packaging waste disposal fee element for red-rated packaging will be twice the amber-rated element; other scheme costs are not modulated.
Conversely, manufacturers that utilise more recyclable packaging formats will benefit from lower charges, as revenue from higher fees levied on less recyclable materials will be redistributed. The overall cost burden for individual producers will therefore depend on the composition of their packaging portfolio and the extent to which they transition to more recyclable materials as defined within the RAM.
Further resources
The current joint regulators’ document is version 8.0, dated 25 February 2026, and applies to data reporting for 2026 onwards. Version 7 remains applicable to 2025 data submissions.
