EPR Fee Modelling

Your packaging design directly affects your EPR fees. See where.

Merchant Packaging estimates your UK EPR fees, shows you which components and materials drive the highest cost, and identifies where recyclability improvements would reduce modulated fees.

Estimated UK EPR fees per component, from its weight, the units dispatched and the rate for its material.
The problem

The fee modulation problem

EPR fees are no longer flat rates per tonne. Increasingly, schemes apply modulated fees based on the recyclability of your packaging. In Germany, ZSVR's minimum standard determines whether a component attracts a standard or penalty fee. In France, CITEO applies bonuses and maluses based on material, recyclability, and inclusion of recycled content. The UK's packaging EPR regime modulates fees based on Recyclability Assessment Methodology (RAM) scores.

The same packaging component can attract a different fee in every market depending on the local recyclability assessment and the scheme's fee structure. If you sell into multiple jurisdictions, the cost impact is not obvious without modelling it.

What we do

What Merchant Packaging does

Merchant Packaging already holds your packaging data at SKU and component level, with a recyclability grade on each component and red, amber or green ratings applied in UK reports. The fee modelling sits on top of this data:

  • See your estimated UK EPR fees, broken down by material and rating
  • Identify which components are the most expensive - the ones driving the highest modulated fees
  • Model "what if" changes on a component and see the effect on its compliance cost - PRNs, disposal fees and Plastic Packaging Tax
  • Apply eco-modulation bonus and malus rules in the France and Germany declarations

This is not a theoretical exercise. The fee structures are published by each scheme. The recyclability grades are already in your data. The modelling connects the two.

Timing

Why this matters now

UK packaging EPR fees landed for the first time in 2025. Businesses saw invoices they were not expecting, driven by material choices and recyclability scores they had not optimised for. The same pattern is repeating across EU markets as eco-modulation rolls out under PPWR. By 2030, recyclability grades (A, B, C) under PPWR Article 6 will directly determine market access - not just fees.

The businesses that model their fee exposure now and redesign proactively will pay less. The ones that wait will pay penalty rates and scramble to reformulate.

Get started

Book a demo to see your fee exposure modelled

Tell us about your packaging portfolio and we will show you where the modulated fees are concentrated.

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Southampton SO14 3TG, UK
Phone+44(0)2380 225 478