Guidance

Extended Producer Responsibility for Packaging: 2025 base fees

Published 27 June 2025

1. Introduction 

This document provides base fees for year 1 (2025 to 2026) of the Extended Producer Responsibility (EPR) for packaging scheme. It relates to fees that would be charged to liable packaging producers by PackUK (the Scheme Administrator). The fees paid by producers will cover PackUK costs and provide local authorities with additional income to cover the cost of recycling and disposal of waste packaging materials. 

It does not cover:

• registration fees and charges paid to the Environment Agency, the Scottish Environment Protection Agency, the Northern Ireland Environment Agency, and Natural Resources Wales
• costs associated with meeting packaging recycling targets e.g. through the purchase of Packaging Waste Recycling Notes 

This document is issued by PackUK as the Scheme Administrator for the four-nation scheme.

2. 2025 base fees

Table 1. EPR for packaging base fees for 2025 to 2026 for all packaging materials

Material	Rate (in £ per tonne)
Aluminium	266
Fibre-based composite	461
Glass	192
Paper and card	196
Plastic	423
Steel	259
Wood	280
Other	259

The base fees are based on the final modelled scenario for the total local authority disposal costs that should be recovered through EPR for packaging in 2025 to 2026 and other relevant costs, detailed below.

The base fees use packaging tonnage data submitted by producers on the Report Packaging Data (RPD) online portal for the full 2024 period as of 9 June 2025, with adjustments applied.

3.  Methodology 

Base fees are calculated by dividing packaging waste management costs (for household packaging waste) and other relevant costs by the total amount of household packaging placed on the market. The result is a fee rate which is expressed in £ per tonne of packaging placed on the market. The following calculation is carried out for each packaging category separately:

Numerator:

(1) Costs incurred by local authorities managing waste of that packaging category (household packaging waste only) minus revenues from material sales, plus
(2) that packaging category’s share of other costs (PackUK costs, communication costs, and debt provision costs).

Denominator: 

Total weight of that packaging category placed on the market (household packaging only). The household tonnages in-scope of producer fees for each material category have been calculated by adding together tonnages that producers reported as household packaging and as packaging commonly disposed of in public bins or littered.

Glass tonnages include household drink containers as they are in scope of EPR for packaging producer fees, unlike single-use Polyethylene Terephthalate (PET), aluminium and steel drinks containers 150 millilitres to 3 litres in size, which are in scope of the Deposit Return Scheme (DRS) for drinks containers across England, Northern Ireland, and Scotland, launching in October 2027.  As details of this scheme and the Welsh DRS are finalised, we will work closely with the four nations and any appointed Deposit Management Organisations to ensure DRS and EPR work effectively.

To note that for the first year of EPR for packaging (2025 to 2026), costs associated with the management of packaging commonly disposed of in public bins or littered will not be included in the numerator. However, the denominator will include both packaging reported as household packaging and packaging reported as commonly disposed of in public bins or littered. 

You should refer to the first release of illustrative base fees for further details on the principles for calculating base fees.

The analytical model used to calculate the total weight of in-scope packaging and to calculate base fees has undergone external quality assurance by the Government Actuary’s Department. The methodology for adjusting to RPD packaging data to best account for producers that have not yet reported has been reviewed by Senior Analysts from each Government in the UK.

4. How this release differs from the previous release

4.1 Differences with illustrative fees   

The base fees published in this document are all within the ranges of illustrative base fees previously published. When compared to illustrative base fees published in December 2024, the differences are due to:

• changes to the tonnages of packaging reported by producers in RPD - this includes the use of data reported by producers for the full 2024 calendar year, rather than for the first half of 2024 as was the case for the December publication
• changes to the way we estimate missing tonnage
• changes to the modelling of local authority costs, including as a result of industry and local authorities’ feedback
• a reduction in the ‘bad debt provision’ fee applied to the total costs, from 6 to 4%

Generally, the base fee rates have fallen since December 2024 (from 8% less for “other” packaging to 39% less for Aluminium). The exception is fibre-based composite fees, which have increased by 1%.

4.2 Regulator checks on RPD data

The packaging tonnage totals included in the base fees calculations represent the most reasonably accurate, in-scope supplied packaging tonnage currently available. 

The regulators have a duty to monitor the accuracy of EPR data submitted into the RPD online portal. This includes engaging with compliance schemes and individual producers to identify and correct possible data errors.  Regulators have also been contacting producers that may have obligations under the Regulations but have failed to report packaging data.  These activities are ongoing.

4.3  Adjustments to 2024 RPD data 

As a result of data checks by regulators, we have made the following adjustments to the RPD data to best account for producers that have not yet reported.

Where producers have not yet reported in 2024 but were fully compliant in 2023, RPD data have been adjusted upward to account for expected increases in tonnage as more producers make submissions into RPD, based on comparing the total 2023 and 2024 reported tonnages.

Where regulators provided us with the number of identified suspected free-rider producers, the following adjustments are applied:

• for English free-riders, we multiplied the number of estimated free-riders by the average UK reported tonnes per producer, which we scale down to account for the fact late reporters usually submit lower tonnages (based on the UK late reporter averages)
• for other nations’ free-riders, we multiplied their respective number of estimated free-riders by the average UK reported tonnes per producer, which we scale down to account for the relevant nation’s average reported producer tonnages
• for those producers who submitted only for one half of the year, we scaled up their tonnages by comparing the total tonnages across the two halves of the year
• RPD data submissions from direct registrants that has been ‘rejected’ by regulators were removed from the dataset given uncertainties in future resubmissions
• RPD data from compliance schemes that have been ‘rejected’ by regulators have been kept in, under the assumption that future resubmissions will not vary significantly from initial submissions

4.4 Local authority costs 

Defra’s ‘Local Authority Packaging Cost and Performance’ model (referred to as ‘LAPCAP’ or ‘the model’ in this document) has been used to calculate base fees. LAPCAP uses a combination of local authority specific data (e.g. tonnes reported in Waste Data Flow) and comparative data (groupings based on reported cost data from a sample of local authorities) to calculate a payment for each local authority in the UK.  The total payment to all local authorities calculated by LAPCAP is the ‘costs incurred by local authorities managing waste’ used in calculation of illustrative base fees. An explanatory note explaining the methodology and procedure used to determine year 1 EPR for packaging payment estimates for local authorities will be published shortly when payment assessments for Year 1 of EPR for packaging are shared with local authorities.

5. Next steps

Details on how fees will be used to invoice producers in October will be shared soon.

Producers have an obligation to continue reporting their packaging data through the RPD online portal. If you are a large producer you should report your data for 1 January to 31 June 2025 by 1 October 2025.

PackUK will use this data and the above listed costs to calculate and release base fees for 2026 to 2027.

6.  Modulated fees to be introduced from 2026 

From year 2 of EPR (2026 to 2027), fees will be modulated to drive a shift to more environmentally sustainable packaging design, using recyclability as the indicator. The types of packaging which will be subject to higher or lower modulated fees will be based on recyclability assessments in line with a Recyclability Assessment Methodology (RAM). All in-scope packaging materials will be assigned a rating of red, amber, or green under the RAM, with red being the least recyclable and green being the most recyclable.

For the first 3 years of the policy, the additional funds raised by the application of a higher modulation factor to RAM red-rated packaging material will form a pot of money for redistribution. This redistribution pot will be used to apply a lower household packaging waste disposal fee for RAM green-rated packaging material. Amber-rated material will see no change in its household packaging waste disposal fee as a result of modulation, remaining at the base fee rate.  

Version 1.1 of RAM was published in April 2025 on GOV.UK. PackUK intends to share a modulation policy statement shortly on GOV.UK.