Packaging EPR 2026: What's Changed and What You Need to Do

Key Changes for 2026

1. Disposal Cost Fees. The biggest change is the introduction of government-set disposal cost fees. These fees are paid directly to the regulator via the PackUK system and cover the cost of local authorities collecting and sorting packaging waste. Fees depend on weight of packaging placed on market, material type, recyclability status, and whether packaging goes to households or businesses. Household packaging attracts significantly higher fees than non-household packaging.

2. Nation of Sale Reporting. For the first time, producers must report where their packaging ends up across the UK's four nations: England, Scotland, Wales, and Northern Ireland. This data determines which devolved administration receives the fee revenue. You must track where final consumers receive your packaged goods.

3. Mandatory Packaging Labelling. From March 31, 2026, most packaging must carry recycling labels informing consumers how to dispose of it correctly. Primary and transit packaging require labelling. Plastic films are initially excluded until March 2027. Labels must be clear, legible, and follow government specifications.

4. Online Marketplace Obligations. Online marketplaces now bear producer obligations for goods sold by overseas sellers on their platforms. This is a major change affecting Amazon, eBay, and similar businesses.

What is Packaging EPR?

Extended Producer Responsibility for packaging shifts the financial burden of waste collection and recycling from local authorities to producers who place packaging on the UK market. The principle is simple: those who create packaging should pay for its end-of-life management.

Under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, businesses must now cover the full costs of collecting, sorting, and recycling the packaging they introduce to the market.

Who is Affected by Packaging EPR?

You have packaging obligations if your business has an annual turnover of one million pounds or more AND handles 25 tonnes or more of packaging, supplies packaged goods under your own brand, places goods into unbranded packaging when supplied, imports products in packaging, operates an online marketplace, hires or loans out reusable packaging, or supplies empty packaging.

Large Producers: Two million pounds or more turnover AND 50+ tonnes packaging. Full reporting obligations, must pay disposal cost fees, must purchase PRNs/PERNs, bi-annual data reporting.

Small Producers: One to two million pounds turnover AND 25 to 50 tonnes packaging. Annual reporting, lighter fee obligations, simplified compliance pathway.

Understanding Packaging EPR Costs

Packaging EPR introduces two main cost components.

Disposal Cost Fees are paid annually to PackUK and regulators. Rates vary by material type (plastic, glass, aluminium, steel, paper, card, wood, fibre-based composite), recyclability status (recyclable vs non-recyclable), and whether household or non-household. For example, recyclable plastic is around 400 to 600 pounds per tonne. Non-recyclable plastic is 800 to 1,200 pounds per tonne. Recyclable paper and card is 100 to 200 pounds per tonne. Glass is 50 to 100 pounds per tonne. These rates are illustrative and subject to annual review.

PRN/PERN Costs: Large producers must still purchase Packaging Recovery Notes or Packaging Export Recovery Notes to prove recycling targets are met. PRN costs fluctuate based on market demand and material type, typically ranging from 10 to 100 pounds per tonne.

The Recyclability Assessment Methodology (RAM)

Packaging EPR introduces the RAM to determine if your packaging qualifies as recyclable for fee purposes. To be considered recyclable, packaging must be collected from at least 75% of households or businesses, be sorted and sent for recycling, be reprocessed into new materials or products, and meet minimum quality standards. Packaging that fails these criteria is classified as non-recyclable and faces higher disposal fees.

Strategies to Reduce Packaging EPR Costs

Improve Recyclability. Design packaging to meet RAM criteria and qualify for lower fee rates.

Reduce Packaging Weight. Lightweight materials directly reduce tonnage and fees.

Switch to Recycled Content. Some fee structures reward use of recycled materials.

Optimise B2B Sales. Non-household packaging attracts lower fees than household.

Review Packaging Designs. Eliminate unnecessary packaging layers and components.

Packaging EPR Compliance Timeline

January 1, 2026: New regulations came into force. March 31, 2026: Labelling requirements begin for most packaging. April 1, 2026: First reporting period begins. October 1, 2026: First bi-annual submission deadline for large producers. January 31, 2027: Annual submission deadline for small producers. March 31, 2027: All packaging must be labelled including films.

How to Calculate Your Packaging Obligation

Step 1: Identify all packaging you handle, including primary, secondary, and transit packaging. Step 2: Determine your activity role as seller, packer/filler, importer, or online marketplace. Step 3: Calculate packaging weight by material across all products sold. Step 4: Split by household vs non-household. Step 5: Assess recyclability using the RAM methodology. Step 6: Allocate to nations based on where packaging ends up geographically.

WERCS Packaging EPR Services

WERCS provides comprehensive packaging compliance support including free obligation assessment and tonnage calculation, registration through approved compliance scheme, bi-annual and annual data reporting, PRN procurement at competitive market rates, recyclability assessments and design guidance, nation of sale reporting support, and fee calculation and budget forecasting.

Need help navigating packaging EPR? Contact WERCS today for expert guidance and competitive compliance solutions.