What pEPR replaced, and why it matters
The old packaging waste regulations worked on shared responsibility: obligation was split across the packaging chain, and producers discharged it by buying Packaging Waste Recovery Notes. The cost was real but modest, and it had almost nothing to say about how the packaging was designed. The recycling obligation has carried on under pEPR - large producers still meet it with notes, now called Packaging Waste Recycling Notes - but it is no longer the whole cost.
pEPR is different in two ways that matter operationally. First, the full net cost of managing household packaging waste sits with producers, which makes the sums an order of magnitude larger. Second, the fee is modulated: two producers reporting the same tonnage of the same material can pay materially different amounts depending on how their packaging is rated for recyclability. That turns packaging data from a reporting chore into a cost driver.
The practical consequence is that the data has to be held at component level. A bottle, its closure, its label and its sleeve are four components with four materials, four weights and potentially three different recyclability ratings. A system that holds packaging weight per product cannot produce a correct submission, and cannot tell you which component is costing you money.
Who is obligated
Obligation depends on two tests, and you have to clear both. One is annual turnover, the other is the tonnage of packaging you supplied to the UK market in the relevant year. Clearing one without the other leaves you outside the scheme.
| Packaging supplied | Turnover £1m or less | Turnover over £1m to £2m | Turnover over £2m |
|---|---|---|---|
| Under 25 tonnes | No obligation | No obligation | No obligation |
| 25 to 50 tonnes | No obligation | Small producer | Large producer |
| Over 50 tonnes | No obligation | Small producer | Large producer |
Both tests have to be met. A business under 25 tonnes is outside the scheme whatever its turnover, and a business under £1m turnover is outside it whatever its tonnage.
The distinction between small and large producer decides how much work the obligation is. Small producers register and report once a year, and are not charged disposal fees. Large producers register, report twice a year, carry out recyclability assessments on their household packaging, and pay the fees.
Check your position
Enter your annual turnover and the tonnage of packaging you supplied to the UK market.
Both figures are needed - the tests are cumulative, so one number on its own decides nothing.
What each submission contains
Submissions go through the Report Packaging Data service. The upload is a CSV, and every line has to carry enough dimensions for the regulator to work out which obligation the tonnage falls under and what fee applies to it.
Each line of the submission is broken down by:
- Material type, mapped to the categories the service recognises rather than to your internal naming
- Weight, which aggregates into the tonnage reported per material category
- Packaging level: primary, secondary or transit
- Intended use: household or commercial, which decides whether disposal fees apply at all
- Activity type, the activity that brought the packaging into scope
- Recyclability rating - red, amber or green - for household packaging, from your RAM assessment
Two of those dimensions cause most of the trouble. The household and commercial split cannot be reconstructed after the fact from a product list, because the same SKU can go both ways depending on the channel it was sold through. And the recyclability rating is a per-component property, so it has to be attached to the component record rather than derived at submission time.
Deadlines
| Deadline | Reporting period covered |
|---|---|
| 1 April | July to December of the previous year |
| 1 October | January to June of the current year |
Small producers report once a year, by 1 April, covering the whole of the previous calendar year.
The dates are fixed, which is the useful thing about them: the work is plannable. What is not plannable is chasing suppliers for missing weights and recycled content figures in the fortnight before a deadline, which is how most producers spend those two windows. The data collection is the long pole, not the submission.
How much it costs
Fees are charged per tonne of household packaging, by material, and modulated by the recyclability rating of the packaging. The amber rate is the base fee. Green-rated packaging pays less than the base, red-rated packaging pays more, and the gap between them widens each year as the modulation multipliers escalate.
| Material | 2025 confirmed | 2026-27 illustrative |
|---|---|---|
| Aluminium | £266 | £270 |
| Fibre-based composite | £461 | £525 |
| Glass | £192 | £205 |
| Paper and card | £196 | £210 |
| Plastic | £423 | £455 |
| Steel | £259 | £290 |
| Wood | £280 | £450 |
| Other | £259 | £225 |
The 2025 column is the confirmed base fee for the first scheme year. The 2026-27 column is the illustrative figure published in December 2025 and is not a confirmed rate - treat it as a planning number, not an invoice.
Wood is the line worth looking at twice. An illustrative move from £280 to £450 a tonne is a 60% increase, and a producer with significant wood packaging who budgeted on last year's rate will be badly out. The fee guide goes through the modulation multipliers and the levers that actually reduce a bill.
RAM: the assessment that sets your rate
Large producers have to assess their household packaging using the Recyclability Assessment Methodology and submit the results with their packaging data. The output is a red, amber or green rating per component: green where there is a recognised route through collection, sorting and reprocessing in the UK, red where there is not, amber in between.
RAM 1.1 applies to packaging supplied through 2026. RAM 2027, published on 1 July 2026, applies to packaging placed on the market from 2027 onwards and does not change 2025 or 2026 obligations. If you assessed your portfolio once at launch and have not revisited it, you are reporting against a methodology that has since moved.
What pEPR is not
pEPR is one of several packaging obligations drawing on the same underlying data, and producers regularly assume a submission to one satisfies another. It does not.
- Plastic Packaging Tax is an HMRC return, assessed per plastic component against a 30% recycled content threshold, on its own schedule
- The EU Packaging and Packaging Waste Regulation applies to what you sell into the EU, with its own recyclability grades, labelling and conformity requirements
- The Deposit Return Scheme, when it launches, needs container volumes and unit counts that pEPR never asked for
- Nation-specific labelling and reporting requirements sit on top of the UK-wide scheme
The common thread is that all of them want the same component-level facts - material, weight, recycled content, recyclability - cut a different way. Which is the argument for holding the data once, in one place, rather than maintaining a spreadsheet per obligation.
Where producers come unstuck
- Holding packaging data per product rather than per component, which makes both the material split and the recyclability rating impossible to state correctly
- Treating a blank recycled content field as zero. A component confirmed at zero and a component nobody has asked about are different states with different fixes, and only one of them is a data problem
- Reconstructing the household and commercial split at submission time from a product list, when it depends on the channel
- Maintaining a separate material mapping per scheme in spreadsheets, where one wrong mapping quietly produces wrong tonnage for a whole material category
- Collecting supplier figures once and never refreshing them. Formulations change between batches, and last period's figure is not evidence for this one
- Assuming a recyclability improvement travels. A change that lifts a component to green under RAM may do nothing for the same component under a national EU methodology
How Merchant Packaging helps
Read next
Sources
- Defra and PackUK: illustrative base fees for 2026-27, December 2025
- PackUK: Recyclability Assessment Methodology
- GOV.UK: packaging waste, extended producer responsibility
Packaging regulation moves. This page states the date it was last reviewed against its sources, and where a figure is illustrative rather than confirmed the text says so.