Packaging design shapes future EPR costs

Extended Producer Responsibility (pEPR) has moved from being a future regulatory requirement to an active business cost for UK food and drink producers. With invoices now being issued and further reporting deadlines approaching throughout 2026, packaging decisions are becoming increasingly important not only for sustainability but also for managing compliance costs.

Understanding the pEPR scheme

The pEPR scheme transfers the cost of collecting and managing household packaging waste from local authorities to the businesses that place packaging onto the UK market. Fees are calculated according to the type and weight of packaging supplied, making packaging strategy an important commercial consideration alongside environmental performance.

Which businesses are affected?

Businesses that meet the turnover and packaging volume thresholds must register, report packaging data and pay annual fees. Larger producers generally have turnover of at least £2 million and handle more than 50 tonnes of packaging annually, while some smaller businesses also fall within the regulations if they exceed the relevant turnover and tonnage thresholds.

Current charging period

How packaging design impacts costs

This shift means packaging design will directly influence future EPR costs. Decisions around material selection, packaging formats, labels, adhesives and multi-material components will all play a greater role in determining compliance fees. Designing with recyclability in mind can therefore deliver both environmental and financial benefits.

Key milestones and reporting deadlines 

March 2026 – UK Packaging PRO becomes the central compliance body

Following its appointment as the Producer Responsibility Organisation (PRO), UK Packaging PRO is the primary point of contact for packaging data submissions, fee calculations and compliance support. Businesses should ensure their registration details are up to date and are prepared to engage with the new system.

1 April 2026 – First major reporting deadline

Businesses obligated under EPR must submit their packaging data by this date. Large producers are required to report packaging placed on the market between July and December 2025, while small producers must submit their full 2025 annual packaging data.

2026–2027 – Modulated EPR fees introduced

The EPR fee structure will move from fixed charges to a red, amber and green rating system based on packaging recyclability. Packaging that is easier to recycle will attract lower fees, while less recyclable formats will incur higher costs. As a result, packaging design and material choices will have a greater impact on compliance costs.

1 October 2026 – Second reporting deadline

Large producers must submit data covering packaging placed on the market between January and June 2026. This deadline also introduces additional reporting requirements for businesses managing their own packaging waste through approved closed-loop recycling systems.

Preparing for compliance

Failure to register, report accurately or pay invoices on time can result in significant financial penalties, making early preparation essential. Reviewing packaging portfolios now allows businesses to identify opportunities to improve recyclability, reduce future EPR liabilities and remain compliant as the regulations continue to develop.