What is EPR? Why Producers will be Facing Higher Fees for Non-Recyclable Packaging
Ensuring your packaging is recyclable is more important than ever, as for the first time, producers are being exposed to annual fees to cover the cost of waste collection, sorting, and treatment of packaging that they put out onto the market.
The first round of invoices associated with Packaging Extended Producer Responsibility (EPR) have been issued to obligated producers in the UK from October 20251.
The first year of EPR fees will be charged at the base material fee, but from next year onwards fees will be modulated based on packaging recyclability2. It is therefore vital for producers to plan ahead in order to mitigate higher costs associated with less recyclable materials.
What is EPR?
Extended Producer Responsibility (EPR) is a key strategy that holds producers accountable for the entire lifecycle of their products, encompassing collection, recycling, and responsible disposal once their useful life ends.
Specifically within the packaging industry, this means businesses that import or supply packaging bear the costs associated with managing packaging waste. This approach actively encourages the design of more sustainable and recyclable packaging solutions, thereby reducing both financial and environmental impacts.
Next year’s waste management fees, which will be invoiced in October 2026, will see the introduction of eco-modulation. This means that the fees charged to producers will vary depending on the recyclability of their packaging. Recyclable packaging will incur lower fees and difficult to recycle packaging will incur higher fees, incentivising sustainable packaging design.
How do I know if my packaging is recyclable?
The recyclability of liable producers’ packaging must be assessed using the Recyclability Assessment Methodology (RAM), which grades it as green, amber or red with ‘red’ packaging meaning it is difficult to recycle at scale and ‘green’ packaging indicating it is widely recyclable in the current UK infrastructure3.
Over time, the higher charges for ‘red’ packaging are set to increase substantially, with difficult to recycle packaging set to reach up to 2x the material base fee in 2028/29. Similarly, packaging rated as ‘green’ under the RAM will benefit from decreasing fees4.
To prove that a packaging product should be evaluated favourably within the RAM, Defra has stated that results from industry-standard testing may be provided to confirm the correct categorisation. Defra has provided one example of such a testing procedure that it deems suitable to be used as evidence to change the RAM output – the CEPI Harmonised Test Methodology and 4evergreen Recyclability Evaluation Protocol5.
Can DS Smith test my packaging?
DS Smith’s Recyclability Evaluation Service (RES) utilises this same CEPI 4evergreen methodology to test any fibre-based packaging product and produce a report and recyclability score ranging from -100 to +100. The service is operated from our Fibre and Paper Development Laboratory, located within the DS Smith Kemsley Paper Mill - the largest paper mill for recycled papers in the UK, with an annual production capacity of around 830,000 tonnes.
RES adheres to the CEPI 4EG testing methodology recognised by Defra, as well as granting obligated producers access to large-scale, real-world recycling experts who are well-equipped to offer in-depth insights about your test results and materials.
If you are interested in discussing our Recyclability Evaluation Service, please contact recyclability.sales@dssmith.com.
Sources:
1. Preparing for pEPR year 1 invoicing: key information for liable producers - GOV.UK
2. Extended Producer Responsibility for Packaging: Modulated Disposal Fees - GOV.UK
3. Recyclability assessment methodology: assessing materials - GOV.UK
4. Packaging Extended Producer Responsibility (pEPR) Producer Disposal Fees Modulation Statement
5. Recyclability assessment methodology: supplementary guidance - GOV.UK