Guidance

Year 2 illustrative waste disposal fees: Extended producer responsibility for packaging

Updated 19 December 2025

This document sets out illustrative waste disposal fees for Year 2 (2026 to 2027) of the Extended producer responsibility (EPR) for packaging scheme. It covers the fees that would be charged to large producers who are liable under the regulations. These fees are set by PackUK, the Scheme Administrator. The fees do not cover: 

• registration fees and charges paid to the Environment Agency (EA), the Scottish Environment Protection Agency (SEPA), the Northern Ireland Environment Agency (NIEA), and Natural Resources Wales (NRW) 

• costs associated with meeting packaging recycling targets, for example the purchase of Packaging Recycling Notes  

The purpose of this document is to give industry early visibility of the likely fees for Year 2. These fees are intended to help with planning but are likely to change significantly as producers submit more data and compliance is monitored by regulators.  

Confirmed fees for Year 2 are expected to be published in June 2026, following the reporting deadline of 1 April 2026 for packaging supplied by registered producers in 2025.   

For the first time, these illustrative fees include estimated modulated fees (green, amber and red) linked to the implementation of the Recycling Assessment Methodology (RAM).  

Read more information about modulation fees in the EPR for packaging modulation fees statement.  

1. Illustrative fees for Year 2 (2026 to 2027) 

Table 1 sets out the current best estimates for illustrative fees for Year 2. Amber fees are set at the base rate (referred to as ‘base fees’ in previous publications).  

Red fees apply to materials that are less recyclable according to the RAM. Red fees are set at 1.2 times the amber fees in Year 2.  

Green fees apply to materials that are more recyclable. The level of discount for green fees depends on the relative proportion of green, amber and red materials reported in the Reporting Packaging Data  (RPD) service.  

Table 1: Current best estimate of EPR for packaging Year 2 illustrative fees (rounded to the nearest £5) for all packaging materials

Material	June 2025 Base Fee	Green fee (in £ per tonne)	Amber fee (in £ per tonne)	Red fee (in £ per tonne)
Aluminium	266	245	270	325
Fibre-based composite	461	475	525	630
Glass	192	185	205	245
Paper and board	196	190	210	250
Plastic	423	415	455	545
Steel	259	260	290	345
Wood	280	410	450	540
Other	259	205	225	270

The fees in bold represent fees that will be charged to greater than 50% of the material group, based on RAM tonnage data submitted. In the table, these are:

• green fees for aluminium, glass, paper and board, steel
• red fees for wood, other

For plastic and fibre-based composites, no RAM category represents greater than 50% of total material tonnage

The full breakdown is set out in Table 3.

‘Other’ includes any materials not listed. For example, bamboo, ceramic, copper, cork, hemp, rubber, silicone.

Table 2: Packaging EPR for packaging modulation factors for Year 2  

Modulated fee discount	% Fee change from amber fee
Red fee	+20%
Amber fee	-
Green fee (illustrative)	-9%

The amber fee is equivalent to the base fee. While the red and amber factors are fixed, the green discount is illustrative as it is dependent on reported packaging data. This % fee change is applied evenly across all packaging material fees. Percentages are rounded to the nearest whole number. 

The fees are based on PackUK’s modelled local authority (LA) disposal costs that should be recovered for Year 2. They are also based on the most recent packaging tonnage data submitted by producers on the RPD service for 2024 and the first half of 2025, as of 1 December 2025, with adjustments applied.  

These represent the best possible point estimate of fees given the information currently available. The fees are subject to change as more information becomes available. These fees are inclusive of Scheme Administrator and impairment cost. The ‘impairment cost’ is the fee or part of the fee charged to a liable producer which the scheme administrator is unable to recover, due to the producer’s insolvency or any other reason. 

When compared with the Year 1 (2025 to 2026) base fees, the Year 2 amber fees have mostly increased, ranging from a 1% increase for aluminium to a 60% increase for wood. The exception is the ‘other’ category, which has decreased by 15%. These changes reflect: 

• an increase in LA costs in line with the Office for Budget Responsibility’s (OBR) Consumer Price Index (CPI) inflation of 1.9%^{[footnote 1]}  

• and an overall decrease in total tonnages in the latest RPD data reported for Year 2, compared to RPD data used to calculate confirmed base fees in June for Year 1 

The increase in the fee for wood is due to a significant reduction in tonnages reported for this material in the latest dataset. Some material previously reported as wood in Year 1 is now being reported under different categories in Year 2. This change in reporting practice has contributed to the sharp percentage increase applied to wood. 

As a result, in Year 2 materials that are less recyclable (rated red) will be charged 20% more than the amber fee. The red fee is a fixed increase of 20%. Current data suggests that materials rated green may receive a discount of around 9%. This discount is provisional and will be adjusted based on the proportions of RAM reported into RPD.

The final figure will be confirmed once the full year of packaging data has been reported in April 2026. Materials that are more recyclable, such as glass, will benefit from the introduction of modulation.  

To demonstrate this, table 3 shows the current RAM proportions reported and the associated average fee paid by each material. These fees proportions remain highly uncertain and are liable to change as producers continue to submit data through the year (see below for more details on RAM uncertainties). 

Table 3: Current RAM proportions for each material and the induced average fee ( taking into account the relative proportion of red, amber, and green for that material)

Material	Proportion red packaging	Proportion amber packaging	Proportion green packaging	Average fee (£)
Aluminium	23%	5%	72%	265
Fibre-based composite	32%	50%	18%	550
Glass	8%	1%	91%	190
Paper and board	21%	3%	76%	205
Plastic	45%	24%	31%	485
Steel	20%	1%	79%	280
Wood	59%	24%	17%	495
Other	84%	6%	10%	260

2. Methodology 

Amber fee calculation 

Amber fees are calculated by dividing packaging waste management costs (for household packaging waste) and other relevant costs by the estimated total amount of household packaging placed on the market for 2025. The result is a fee rate expressed in £ per tonne of packaging placed on the market.

This calculation follows the same approach as the base fee calculation used in Year 1 and is carried out for each packaging category separately.   

The numerator is calculated by adding: 

• efficient costs incurred by local authorities managing waste of that packaging category (household packaging waste only) minus revenues from material sales, plus  

• the packaging category’s share of other costs, which are PackUK administration costs, public information costs, and debt provision costs 

The figure is then divided by the denominator which is the total estimated weight of that packaging category placed on the market as household packaging only.  

Household tonnages in-scope of 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.

Single-use Polyethylene Terephthalate (PET), aluminium and steel drinks containers between 150ml and 3 litres are not included in the tonnages of their respective material categories because they are in scope of the respective Deposit Return Schemes (DRS) across England, Scotland, Northern Ireland and Wales.   

In Year 2, 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 includes all reported household packaging, including packaging reported as commonly disposed of in public bins or littered. This is in line with the regulations and reflects how fees were calculated in Year 1. 

Further explanation on why materials have different fees, and additional background can be found in the first publication of illustrative base fees, published in August 2024. 

Costs incurred by local authority  

PackUK’s ‘Local Authority Packaging Cost and Performance’ model (LAPCAP) has been used to calculate illustrative fees. LAPCAP calculates a payment for each LA in the UK using a combination of: 

•  LA specific data, such as the tonnages reported in Waste Data Flow 

• comparative data (groupings based on reported cost data from a sample of LAs)  

 The total payment to all local authorities calculated by LAPCAP is the ‘Costs incurred by local authorities managing waste’ used in calculation of illustrative fees. 

 An explanatory note setting out the methodology used to determine Year 2 EPR for packaging payment estimates for local authorities will be published soon. 

Estimating total 2025 packaging tonnages 

The deadline for producers to submit their packaging data for 1 January to 30 June 2025 (the first half of 2025) was 1 October 2025. The deadline to submit packaging data for the rest of 2025 (Year 2) is 1 April 2026.  

To calculate the illustrative fees, the total expected packaging for 2025 has been estimated using the latest packaging data submitted into RPD for both 2024 and the first half of 2025. To do so, the current total packaging weights for each material reported in 2024 are scaled up or down to reflect changes in reporting for that material between the first half of 2024 and the first half of 2025. 

This methodology assumes that: 

• the changes in reporting between the first half of 2024 and the first half of 2025 are representative of changes across the whole of 2025   

• seasonal trends seen in 2024 between the first half and second half of the year will be repeated in 2025 

This methodology, which adjusts RPD packaging data to extrapolate the first half of 2025 data for the whole year and accounts for producers that have not yet reported, has been reviewed by senior analysts from the devolved governments and the Regulators. 

Red fee calculation 

The red fee is a fixed multiplier of the amber fee. In Year 2, which is the first year of modulation, this multiplier will be 1.2 times the amber fee. This will increase to 1.6 times in Year 3 (2027 to 2028) and 2 times in Year 4 (2028 to 2029) as the scheme supports more environmentally sustainable packaging design. 

The red fee (like the amber fee) is independent of the proportions of red, amber and green packaging reported by producers.  

Red medical packaging that is red by virtue of regulatory requirement is incorporated into the amber total tonnage for the purposes of calculating illustrative fees, as per the modulation policy statement. 

Green fee calculation 

The additional funding brought in from the increased red fee are used to discount green fees so that the total cost of the scheme remains fixed. The additional fees brought in are shared equally across all materials, which means all materials get the same green discount.  

The green discount is calculated by dividing the additional revenue brought in from red materials (the numerator) by the total revenue for green materials when charged at the base rate (the denominator).  

The following calculation is carried out across all materials to calculate the overall green discount rate: 

The numerator is the extra fund collected from red rated materials. This is calculated as:  

• the total fund from red rated materials at the red fees  

• minus the total fund from those same red rated materials if they were charged at the base (amber) rate 

This means that the green discount is higher as more red material is placed on the market. 

This is divided by the denominator which is the total fund from green materials if they were charged at the base fee (amber) rate. 

The green fee for each material is the amber fee discounted at the green discount rate. The green fee is dependent on the proportions of red, amber, and green materials placed on the market. If more green materials are placed on the market, the green fees increase, whereas if fewer green materials are placed on the market, the green fees reduce.  

Only the disposal fees which cover the LA costs are modulated. The other costs associated PackUK administration costs, public information costs, and the debt provisions are calculated as in the Amber fee 

Further detail can be found in the modulation policy statement. 

Estimating total RAM proportions 

To support industry by providing more time to collect data on their packaging under the RAM categorisation, Regulatory Position Statements (RPS) (called the Regulatory Statement in Wales) were issued by each of the UK Environmental Regulators. These statements set out the circumstances where no action would be taken if producers failed to report their RAM categorisation data  for period 1 January to 30 June 2025. This means that a full data set is not available for the first half of 2025. 

The illustrative green fees are therefore calculated using the current reported RAM proportions in RPD from producers who have submitted RAM for the first half of 2025 as of 1 December 2025. That data shows that of the packaging data submitted against the RAM, 71% is green, 8% is amber, and 21% is red.  

Due to the RPS, this only represents a subset of producers and is likely to change as: 

• producers continue to submit their packaging and RAM data throughout the year 

• regulators complete their data checks 

In future years, 6 months RAM data will be available at the point of calculation, and the proportion will be based on the full set of producer submissions.  

3. Regulator checks on RPD data 

The packaging tonnage totals included in the illustrative fees’ calculations represent the most accurate in-scope supplied packaging tonnage currently available.  

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

The environmental regulators periodically publish the latest data in RPD. These figures represent the latest packaging data in RPD at the time of publication. They do not include adjustments to account for producers who are yet to report their packaging data or to extrapolate partial data to the full-year equivalent. As such, the data shown there will differ from the data used to calculate the illustrative fees in this document. 

4. Uncertainties with RPD data 

The key sources of uncertainty with the illustrative fees are as a result of the following issues:

1. RPD tonnage data for Year 2 is only available for the first 6 months and may change as a result of late submissions and further resubmissions of data. 

2. For the purpose of extrapolating this data to a full year, we have assumed that seasonal patterns of reporting in Year 1 will also apply in Year 2, and that if less tonnages were reported for the first 6-months of 2025, the same trend would apply to the second 6-months of data. These patterns may however be different for Year 2. 

3. RAM reports for the first six months of 2025 were not submitted by all producers. We have assumed that the final proportion of green, amber and red materials for Year 2 will be the same as the RAM data available at the time of publication. This dataset accounts for 45 percent of the total tonnage submitted for the first half of 2025. This assumption may be inaccurate, but it is the most appropriate at this time and the green discount may change. 

5. How Year 2 illustrative fees have changed from Year 1 confirmed fees  

Introduction of modulated fees 

From Year 2, fees are modulated to drive a shift towards more environmentally sustainable packaging design, using recyclability as the indicator. Packaging items are subject to higher or lower modulated fees based on recyclability assessments in line with the RAM. All in-scope packaging materials must be reported by producers as red, amber, or green under the RAM, with red being the least recyclable and green being the most recyclable. 

The methodology has been outlined for the first three years of the scheme, with fees for RAM red-rated packaging materials modulated upwards to ensure that less recyclable material takes on a greater share of liability under the scheme. This enables a reduction in the share of liability for the most recyclable materials, resulting in a lower household packaging waste disposal fee for 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 and PackUK modulation policy statement was published in June 2025. 

Differences in reported packaging tonnages in RPD 

The increase in illustrative amber fees, when compared to the Year 1 confirmed base fees, is driven largely by a decrease in tonnages reported in RPD between the calculation of confirmed base fees in June and RPD data submitted by producers for 2025 as of 1 December 2025. RPD data for 2024 and 2025 is subject to further changes due to producers’ late submissions and resubmissions. These changes are likely to affect the difference between Year 1 confirmed base fees and Year 2 illustrative fees. 

Since June, there have been reductions in packaging tonnages reported in 2024. There have also been small changes in reporting between the first half of 2024 and the first half of 2025. The only exception is the ‘other’ material group, which has seen a 28% percent increase. These changes have been reflected in the estimation of total 2025 tonnages from total 2024 tonnages.  

LA costs 

Following feedback from LAs on their Year 1 Notices of Assessment, several changes have been made to the LAPCAP model for Year 2. These include: 

• inflation applied to outputs to align with 2026 to 2027 

• adjustment of HWRC and Bring Site tonnages for Scottish LAs  

• adjustment of residual tonnages for Scottish LAs  

• adjustment of Northern Irish disposal tonnages  

• adjustment of Waste Disposal Authority (WDA) household numbers  

• adjustments to a number of LAs’ recycling credits 

• adjustments to some LAs’ FlexCollect payments where necessary 

• adjustments to move funds between Waste Collection Authority (WCA) and WDA to take into account individual arrangements 

• adjustments to reflect costs of managing flexible plastics for recycling 

6. Next steps 

Producers have an obligation to continue reporting their packaging data through the RPD service. If you are a large producer, check deadlines for reporting packaging data. 

PackUK will use this data and the costs listed above to calculate and publish confirmed fees for 2026 to 2027. This is expected to be in June 2026.

1. See Economic and fiscal outlook – March 2025 - Office for Budget Responsibility. The value is given by cell E133 in table 1.7 in ‘Detailed Forecast Tables: Economy’. ↩