UK businesses gained clarity on the financial obligations stemming from the nation's Extended Producer Responsibility for Packaging (pEPR) scheme in an announcement from PackUK in June. With fees set to be implemented for the first time in October 2025, pEPR fundamentally shifts the financial burden of managing household packaging waste from local taxpayers directly to the businesses that produce and use it.
On June 30th, PackUK released a suite of publications including confirmed 2025 base fees, a fee modulation policy, a regulatory position statement and an interim strategy.
New fees confirmed: what businesses will pay
Producers now have certainty regarding the 2025 base fees, ahead of the first invoices expected this October. Notably, most fees have seen a reduction compared to earlier illustrative figures. This positive adjustment is attributed to high levels of industry data reporting compliance and validation efforts by industry, regulators and PackUK. The 2025 base fees are calculated using 2024 packaging tonnages reported by producers and local authority waste management costs, following a robust, stakeholder-tested methodology.
The EPR scheme forms a cornerstone of the UK’s broader EPR regulations, which industry leaders estimate will generate over £10 billion in recycling infrastructure investment and support 25,000 jobs over the next decade.
Fee modulation: rewarding sustainable packaging
Beyond the immediate fees, PackUK’s newly published Producer Fee Modulation Policy Statement introduces a powerful incentive for businesses to adopt more environmentally sustainable packaging. Starting from the 2026/27, this policy will adjust producer fees based on packaging recyclability, as assessed through the Recyclability Assessment Methodology (RAM).
The implications for businesses are clear: packaging rated as “RAM Green” (highly recyclable) will benefit from progressively decreasing fees, offering a financial advantage. Conversely, “RAM Red” (poorly recyclable) packaging will face escalating fees, with modulation factors increasing over three consecutive years (1.2x, 1.6x, and 2.0x).
This mechanism directly supports the “polluter pays” principle, ensuring companies creating less sustainable packaging bear a greater financial responsibility, while rewarding those making positive design choices. Medical packaging, where regulatory requirements limit recyclability, will have special provisions. This three-year framework aims to provide businesses with the stability needed to make informed investment decisions in packaging design and materials.
Easing the transition: regulatory flexibility
In response to industry feedback concerning the time and resources required for 2025 recyclability assessments, environmental regulators across the four nations have issued a Regulatory Position Statement. This provides businesses with additional flexibility during the transition, allowing them to extrapolate recyclability assessment obligations for the first half of 2025 from second-half data. This measure aims to ease the administrative burden while maintaining the commitment to introduce modulated EPR fees from 2026 to 2027.
Pack UK’s interim strategy, also released today, outlines its immediate operational plans as the scheme administrator. A more comprehensive long-term strategy, detailing governance and broader UK policy objectives, is expected later in 2025.
Share this article:
