For the first year of UK packaging EPR, recyclability was something you reported. From the second year, it is something you pay for. The red, amber or green rating each component receives under the Recyclability Assessment Methodology now sets the rate charged on its tonnage, and two producers reporting the same weight of the same material can receive materially different bills.

Large producers submitted their January to June 2026 data, with RAM assessments attached, by 1 October. That submission is the first one where the ratings carry a price. This post sets out what changed between year one and year two, why the ratings you submitted may not be the ones you would choose to defend, and how to check an invoice against your own data.

What changed between year one and year two

Fees are still charged per tonne of household packaging, by material. What changes is that the per-tonne rate is no longer one number per material. The base fee is now the amber rate. Green-rated packaging pays below it and red-rated packaging pays above it.

The illustrative position for 2026-27, published by Defra and PackUK in December 2025, put the green rate roughly 9% below the base and the red rate roughly 20% above it. On the illustrative plastic base fee of £455 a tonne, that is around £415 for green and £545 for red - a spread of about £13,000 on every 100 tonnes of the same material.

Those figures were published for planning and are not confirmed rates. Confirmed rates follow the reporting deadline for the previous year's data, so check the current position with PackUK before treating any of them as an invoice. The base fees by material, and how they moved between the first two scheme years, are kept current in our UK EPR fees guide.

The rating you submitted may not be the rating you would defend

Most large producers ran a recyclability assessment at the start of the scheme, when the ratings did not yet carry a cost. Many have not revisited it since. That was a reasonable place to stop when the rating was informational. It is an expensive place to stop now.

There are three common ways a rating drifts out of line with the packaging it describes:

  • The component changed and the assessment did not. A supplier swapped a coating, a label material or a closure, and the rating was never rerun against the new specification
  • The assessment was made at the wrong level. A rating held per product rather than per component averages a red closure into an otherwise green pack, or the reverse, and the wrong rate is applied to the whole weight
  • The methodology moved underneath it. Reporting for 2026 uses RAM 1.1, and the version that applies to 2027 supply may rate the same component differently. A single recyclability field cannot hold both

Checking the invoice against your own data

An invoice is the scheme administrator's arithmetic applied to your submission. The arithmetic is rarely the problem. The problem is whether the submission it was built from is one you can stand behind.

The check is straightforward if your data is held at component level. Rebuild your household tonnage by material and by rating from your own records for the same period, apply the published rates, and compare the result with the invoice. Differences come from one of three places: the tonnage, the rating mix, or a submission that does not match what your records now say.

If you cannot rebuild the figure, that is the finding. A producer that can only see packaging weight per product, or ratings in a spreadsheet with no record of when or under which version they were made, has no way to tell a correct invoice from an incorrect one.

Where a red rating costs the most

Red ratings concentrate in a predictable set of formats: flexible plastic films and pouches, multi-material laminates that cannot be separated, dark or carbon-black plastics that sorting equipment cannot detect, and components with coatings or labels that compromise the base material.

Because the fee is per tonne, the cost of a red rating scales with weight and with the base rate of the material. A heavy red component in an expensive material is worth more redesign effort than a light one in a cheap material. Ranking components by the difference between their current rate and the rate they would pay at the next rating up is the most direct way to decide where packaging development time goes.

Weight is the other lever, and it works at any rating. A lighter component pays less whether it is red, amber or green.

What year two does not change

Modulation changes the cost of the data. It does not change the reporting obligations around it:

  • Large producers still report twice a year - January to June by 1 October, July to December by 1 April
  • Small producers still report once a year and do not pay disposal fees
  • The turnover and tonnage thresholds that decide which group you are in are unchanged
  • A UK RAM rating still says nothing about the same component in another market. Germany, France and the Netherlands each assess recyclability against their own standard, and an improvement in one does not carry across

How Merchant Packaging supports this

Merchant Packaging records a recyclability grade per component with the basis it rests on, the date it was made and when it expires, and applies red, amber or green ratings when UK reports run. Bills of materials are versioned with an effective-from date, so the packaging behind any submission can be rebuilt for the period it covers.

EPR fee estimation applies the fee rates per material category and rating to that data, which means an invoice can be checked against your own records rather than accepted on trust, and the fee optimisation report shows what moving a component from red to amber or amber to green is worth before the redesign is commissioned.