Packaging EPR disposal fees become recyclability-based for 2026 to 2027: what producers will pay

What eco-modulation means for pEPR fees

Scheme year 2026 to 2027 is the first year in which disposal fees under the UK Extended Producer Responsibility for packaging (pEPR) are eco-modulated — that is, adjusted up or down based on how recyclable your packaging is. The legal basis is regulation 64(7)(c) of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.

Previously, all producers paid a flat fee per tonne for each material type. From 2026 to 2027, fees are set against a red–amber–green (RAG) recyclability rating determined by the Recyclability Assessment Methodology (RAM) version 1.1:

• Green (good recyclability) — approximately a 9% discount against the Amber baseline fee.
• Amber (medium recyclability) — the baseline fee.
• Red (poor recyclability) — a 1.2× multiplier applied to the baseline fee in 2026 to 2027, rising to 1.6× in 2027 to 2028 and 2.0× in 2028 to 2029.

The scheme is a UK-wide four-nation framework. It is jointly made by the four UK governments and administered by PackUK. Enforcement in England is by the Environment Agency; equivalent regulators cover Scotland (SEPA), Wales (NRW), and Northern Ireland (NIEA). The fees, the RAM methodology, and the RAG rating system are identical across all four nations — only the enforcing body differs.

Who is in scope: large producer and small producer thresholds

pEPR obligations — including eco-modulated disposal fees — apply to large producers: businesses with annual turnover of £2 million or more AND 50 tonnes or more of packaging supplied or imported in a year. Both conditions must be met.

Small producers — businesses with £1 million or more turnover AND 25 tonnes or more of packaging — have lighter reporting duties but are not liable for the eco-modulated disposal fees.

Businesses below the small-producer threshold are not in scope and have no pEPR obligation. If your business is close to either threshold, check your packaging tonnage figures carefully before concluding you are exempt.

How to reduce your disposal fees: improving your RAM rating

The RAM rating for each of your packaging formats determines whether you pay the Green discount, the Amber baseline, or the Red premium. There are practical steps you can take to improve ratings before the confirmed June 2026 rates are applied to your invoices:

• Review packaging design. Mono-material formats are generally easier to recycle than multi-layer laminates, so switching where feasible can improve your RAG rating. Removing non-recyclable components (labels, inks, or adhesives that impede recycling) may also shift a format up a tier under the RAM criteria.
• Assess every packaging format against RAM v1.1. Check each material type you place on the market against the RAM v1.1 criteria and submit your recyclability data to PackUK. Do not focus only on your highest-volume materials — a poor rating on a lower-volume line still attracts the Red premium.
• Work with your compliance scheme. If you report through a packaging compliance scheme rather than directly, your scheme can advise on the RAM submission process and the data PackUK requires.
• Plan changes ahead of 2027 to 2028. The Red multiplier rises to 1.6× in 2027 to 2028 and 2.0× in 2028 to 2029. Packaging redesign takes time; begin the process now to capture savings in future scheme years.

Note that the per-tonne figures published in December 2025 are illustrative. Confirmed Year 2 fee rates will be published by PackUK in June 2026 and those are the rates that will appear on your invoices.