Base fees for Extended Producer Responsibility (EPR) introduced

PackUK has released several publications central to the delivery of the UK’s Extended Producer Responsibility (EPR) for Packaging scheme.

Confirmed 2025 base fees

PackUK has published the 2025 base fees for the Extended Producer Responsibility for packaging (pEPR) scheme, providing crucial certainty to producers ahead of the first invoices in October 2025.

Following three previous illustrative publications of estimated fees, these confirmed base fees represent a significant milestone in the implementation of the UK’s circular economy transition.

Nearly all fees have reduced compared with the illustrative base fees published in December, with glass down by 20%. The reductions result from high levels of industry compliance with reporting obligations and extensive work across the regulators and PackUK to assure and validate the data provided. The 2025 base fees are calculated using packaging tonnages reported by producers for 2024 and local authority waste management costs. The methodology has been tested with stakeholders including producers, compliance schemes and local authorities.

Alongside the confirmed base fees, PackUK has also published the Modulation Policy Statement, which outlines how fees will be adjusted from 2026 onwards to incentivise the use of more recyclable packaging.

The pEPR scheme forms the cornerstone of the UK’s packaging reforms, which the leaders of the UK’s largest waste management companies have said will support 25,000 jobs, stimulate more than £10bn investment in recycling capability over the next decade and fund improvements to household recycling services across the UK.

Producers can access further guidance on the gov.uk website to understand how these fees will affect their businesses. PackUK will hold a Base Fees themed webinar on Thursday 10 July 2025. You can sign-up to register your attendance.

Fee Modulation Policy Statement

PackUK has published its first Producer Fee Modulation Policy Statement for the Extended Producer Responsibility for packaging (pEPR) scheme. This policy represents a significant step forward in incentivising the use of environmentally sustainable packaging across the UK.

The new modulation policy establishes a clear three-year framework that will adjust producer fees based on packaging recyclability, as assessed through the Recyclability Assessment Methodology (RAM) ratings. Starting from the 2026/27 financial year, the policy will apply escalating modulation factors of 1.2x, 1.6x, and 2.0x over consecutive years.

What this means in practice:

• Producers of RAM Green-rated (highly recyclable) packaging will benefit from steadily decreasing fees
• Producers of RAM Red-rated (poorly recyclable) packaging will face progressively higher fees
• Special provisions apply for medical packaging where regulatory requirements limit recyclability options

This approach maintains the total revenue generated by pEPR fees while creating meaningful financial incentives for producers to switch to more recyclable packaging options. By setting out a three-year plan, the policy provides industry with the certainty needed to make informed investment decisions and operational changes.

The modulation policy directly supports the core principles underlying the pEPR scheme – ‘polluter pays’, rectification at source, and prevention. It ensures that producers creating less environmentally sustainable packaging bear appropriate financial responsibility, while rewarding those making positive choices.

PackUK has stated it will conduct further research to potentially incorporate additional environmental sustainability factors in future policy iterations, continuing to drive innovation and improvement in packaging design across the UK.

Regulatory Position Statement

In response to industry feedback regarding the time and resource required to meet their 2025 recyclability assessment obligations, the four nations’ environmental regulators have published a Regulatory Position Statement (in Wales, a Regulatory Decision) providing additional flexibility for producers during this transition.

This aims to ease the burden while maintaining the commitment to introduce modulated pEPR fees from the 2026–2027 assessment year. While producers must still report tonnages for the first half of 2025 including flexible and rigid plastics separately, their recyclability assessment obligations for this period can be extrapolated from second-half data.

The initial modulation policy statement covers the three years from assessment year 2026/27 until 2028/29. During this period, fee modulation will be initially based on recyclability only through the Recyclability Assessment Methodology (RAM).

Following this and in line with the requirement for a review of modulation after three years, PackUK will research how modulation might incorporate additional sustainability factors, with the possibility of incorporating these into modulation after this period.

PackUK interim strategy

In setting up the pEPR scheme PackUK, as Scheme Administrator, is required to publish a strategy meeting the requirements set out in Paragraph 11 of Schedule 7 to the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.

This is an interim strategy, which has been approved by approved by officials from all four nations and devolved ministers in parallel for agreement.

A long-term strategy will be launched later in 2025 to include:

• Long-term structures and arrangements (imminent appointments of Chief Executive Officer and Chief Strategy Officer)
• Developments to UK-wide policy objectives over the coming months e.g. work in reuse, the Local Government Outcomes Framework for England
• Planned appointment of a Producer Responsibility Organisation by March 2026

Together, these measures mentioned outlined above represent a cornerstone of the government’s wider packaging initiatives, which collectively aim to support 25,000 jobs and stimulate more than £10bn in recycling infrastructure investment over the next decade.

Commenting on the announcement, Jim Bligh, Director of Corporate Affairs and Packaging, The Food and Drink Federation said: “These fees provide welcome clarity for manufacturers on the costs they will be facing for the first year of EPR. At £1.4bn a year, EPR is an expensive programme. So, it’s critical that government demonstrates to industry how the scheme will deliver value for money, improve the UK’s flatlining recycling rates and build the circular economy that packaging producers expect.

“The UK government beginning to set out measures to ensure that local councils only spend EPR fees on packaging recycling is a welcome step in the right direction. We look forward to seeing further detail on how this will be enforced and applied across both Scotland and Wales.”

However, for some the scheme does not go far enough. A spokesperson for glass manufacturer, Encirc, added: “The government needs to hit the pause button on this scheme before British glass manufacturers are unfairly hit with these disproportionate costs.

“Sadly the government’s pricing structure has not taken into account that glass is far more sustainable than plastic and weighs considerably more. Ministers must continue dialogue with the British glass industry before implementing EPR. It is in the best interest of consumers, businesses and glass factories for this scheme to be put on ice.”