Extended Producer Responsibility (EPR) for packaging shifts the cost of dealing with household packaging waste from local authorities to the organisations that place packaging on the UK market. In practice, that means new data duties, new fees, and (from 2026) modulated charges linked to recyclability. Below is a concise overview of what changes, who is in scope, and when—plus the operational implications many teams are working through right now. 

Key milestones and payments

• Base fees for 2025 have been confirmed, with invoices scheduled for October 2025. Fees are calculated by PackUK using 2024 tonnage data and local authority cost models. 

• Modulated fees start from 2026 (Year 2 of EPR). Packaging will attract higher or lower charges based on a Recyclability Assessment Methodology (RAM), using a red/amber/green rating. 

Who is affected?

EPR applies to UK organisations that import or supply packaging and pass the turnover/tonnage thresholds.

• Large producers (≥£2m turnover and >50t packaging) report bi-annually, pay the waste management (disposal) fee, regulator charges, and still need PRNs/PERNs to meet recycling obligations.

• Small producers (between £1m–£2m turnover, >25t; or >£1m and 25–50t) have lighter duties but still report.
  Regulatory guidance sets out activities in scope (brand owner, packer/filler, importer, online marketplace, etc.). GOV.UK

PRNs/PERNs continue alongside EPR: producers still need evidence notes to meet recycling targets from 2025 onwards (with specific rules on accreditation year usage). 

Data you must submit (and when)

• Reporting periods & deadlines (large producers):

  • H2 2024 data was due 1 April 2025.

  • H1 2025 data is due 1 October 2025. 

• Small producers: 2024 data due 1 April 2025; 2025 data due 1 April 2026. 

• Nation data: where packaging is supplied/discarded in the UK—2025 nation data due 1 April 2026. 

• Recyclability (RAM) data: from 1 January 2025, large producers supplying household packaging (and certain public-bin/glass items) must assess and report recyclability (R/A/G) using RAM; these ratings feed into 2026 modulation. 

What the 2025 base fees look like

Year 1 base fees (£/tonne) apply by material (e.g., plastic, glass, paper/card, aluminium, steel, wood, fibre-based composites, “other”). For example, plastics carry a higher base fee than glass/paper due to cost differentials in managing household packaging waste. (PackUK has published the full table and methodology.) 

What changes in 2026?

From 2026, modulation adjusts the disposal fee up or down based on recyclability (RAM):

• Green (widely recyclable) → lower fee than base

• Amber → broadly at base

• Red (hard to recycle at scale) → higher fee; early years include a redistribution pot to offset greener materials. 

Practically, this links packaging design choices (format, material, components) to a direct cost signal. Expect procurement and packaging engineering teams to collaborate more closely on specifications, labelling, and data capture. 

Interactions with other policies

• The Deposit Return Scheme (DRS) for drinks containers is scheduled to launch October 2027 across England, Northern Ireland and Scotland (with separate arrangements for Wales). EPR and DRS are designed to dovetail (e.g., some drinks containers are within DRS rather than EPR fee scope). 

What businesses should do now

• Tighten data systems. Ensure you can classify household vs non-household, track material/format, and generate bi-annual submissions on time. The RPD (Report Packaging Data) service and gov.uk templates are live. 

• Map your fee exposure. Use the 2025 base fees and 2024 volumes to estimate charges; then scenario-test 2026 under RAM (what turns amber into green?). 

• Review packaging specs and labelling. Prepare for modulated fees by prioritising widely recyclable formats and eliminating “automatic red” features where feasible. 

• Align PRN strategy. PRNs/PERNs remain part of compliance; check accreditation-year rules and any December flexibilities noted by regulators. 

• Engage supply chain & finance early. The cost signal lands with invoices in Oct 2025; procurement and suppliers should understand implications now. 

• Common questions we’re hearing

  • Will fees increase overall? Government modelling uses local authority costs and producer tonnages; the distribution across materials reflects those costs. The modulation layer from 2026 further differentiates based on recyclability. 

  • Do micro-brands/smaller volumes escape? Thresholds determine whether you are classed small/large and which duties apply, but many SMEs still need to report (annually) and may share group-level obligations. 

  • How detailed does recyclability data need to be? RAM requires an assessment by material category and component, producing a red/amber/green output that will influence 2026 fees. 

  Hear from specialists at The Recycling Expo

  Strong opinions on this issue? You’re not alone.
  Speak with experts who are actively helping producers and retailers navigate EPR data, fees and packaging design:

  AMCS Group; Beyondly Global Limited; Buss ChemTech; Clearpoint Recycling Ltd; Recolight; Vanden Recycling Ltd; Packaged Solutions — and hundreds of other exhibitors on the show floor. 

  📅 7–8 October 2025 | ExCeL London
  🎟️ Register free: recyclingexpo.co.uk