EPR fees are now on your invoice. How a lighter case reduces them

The Extended Producer Responsibility scheme for packaging has moved from consultation to cash. Large producers, broadly those with turnover above £2 million placing more than 50 tonnes of packaging on the UK market, received their first invoices from PackUK in the autumn of 2025 for the 2025 to 2026 scheme year. For paper and board the confirmed base fee was £196 per tonne. For fibre based composites, where fibre is combined with plastic or other layers, it was £461. Plastic came in at £423, glass at £192, and so on down a list that, for the first time, put a price on the material choices that packaging buyers had made without much reference to what happens after the bin.

The fees apply to household packaging, meaning packaging that ends up in a domestic waste stream. Transit packaging that moves between businesses and is disposed of commercially is reported but doesn't attract the disposal fee. That distinction matters, because for a manufacturer selling into retail or direct to consumers, the outer case, the shelf ready tray and the e-commerce mailer are all household packaging, and the tonnage adds up quickly.

What changes in year two

In December 2025 PackUK published its illustrative fees for the 2026 to 2027 year, and they introduced the thing the scheme was always building towards: modulation. From year two, every item of packaging is rated red, amber or green under the Recyclability Assessment Methodology, and the fee follows the rating. Amber is the base fee. Red is set at 1.2 times amber. Green attracts a discount that depends on how much red material the rest of the market puts through, illustrated at around 9%.

For paper and board the illustrative year two figures are £190 per tonne for green, £210 for amber and £250 for red. Confirmed fees are due in June once the full year of 2025 data has been reported. The numbers themselves are less important than the direction of travel. The red multiplier is fixed at 1.2 in year two, rises to 1.6 in year three, and reaches 2.0 in year four. A producer whose packaging is rated red will, within three years, be paying double what a neighbour with green rated packaging pays for exactly the same weight of material. And under the reporting rules, packaging with missing or incomplete recyclability data defaults to red.

The encouraging news for anyone using corrugated is that the material starts from a strong position. Of the paper and board tonnage reported with a recyclability rating so far, 76% is green. Plain corrugated, uncoated and unlaminated, is about as recyclable as packaging gets. The risk sits at the edges, in coatings, film laminations, wax treatments and the sort of finishing that can move an item out of paper and board altogether and into the fibre based composite category, where the illustrative amber fee is £525 a tonne rather than £210. A design decision made for shelf appeal can more than double the fee on the case it sits on.

The arithmetic of weight

The fee is charged per tonne, which means every gram of board you put on the market is now a gram you pay to have collected and processed at the other end. That turns case weight from a cost of goods question into a compliance question as well, and it makes the case for reviewing specifications considerably stronger than it was two years ago.

Consider a business shipping a million cases a year, each weighing 450 grams. That's 450 tonnes of household packaging. At the illustrative amber fee of £210 a tonne the EPR bill on those cases is £94,500 a year. Take 10% out of the weight, whether through a lighter board grade that still meets the performance requirement, a smaller footprint that removes void, or a change of flute that achieves the same crush resistance with less fibre, and the fee falls by £9,450. That's real money, and it's money that didn't exist as a saving before 2025.

What's more interesting is that the EPR saving is the smaller part of the prize. The board itself costs several times more per tonne than the fee for disposing of it, so the same 10% weight reduction takes considerably more out of the material bill than it does out of the PackUK invoice. EPR didn't create the opportunity, but it has put a second price tag on one that was already there and made it much harder to ignore.

Designing the fee down

In practice there are five places to look. The first is board grade, where specifications set years ago for a heavier product or a rougher journey tend to persist long after the reason for them has gone. The second is flute profile, because the same box in a different flute can be lighter for equivalent stacking performance. The third is footprint, since a case designed around the product rather than around the nearest standard size carries less board and less void fill. The fourth is finishing, where every coating or lamination should be asked whether it earns its place, now that it may cost £315 a tonne more than the board beneath it. The fifth is data, because a rating of red by default is entirely avoidable and entirely expensive.

None of this requires compromising on protection. A specification that's too light fails in transit, and the damage costs far more than the EPR saving. The point is to specify from what the product actually needs, with the fee modelled alongside the material cost at the design stage rather than discovered on an invoice eighteen months later.

That's how we work. When we recommend a specification we calculate its EPR liability per unit and per SKU, using the current published rates, and we show it beside the material cost so the whole commercial picture is visible before anything goes to production. When PackUK confirm the year two fees in June the model updates and the numbers move. Very few of our customers were thinking about their packaging in tonnes two years ago. All of them are now, because the invoice arrived.