Packaging EPR Fees: Why Recyclability Matters

How packaging EPR fees are changing under eco-modulation

Until now, every producer paid a flat rate per tonne of each packaging material. For 2026/27 that ends. The disposal-fee element of your EPR fees will be adjusted, or modulated, based on how recyclable your packaging is.

The tool behind this is the Recyclability Assessment Methodology, usually shortened to RAM. It rates each in-scope packaging item as green, amber or red. Modulation begins in year 2 of the scheme, covering the 2026/27 disposal-fee calculations, and it uses data on the packaging you supplied during 2025.

One point worth being clear on. Modulation applies only to the household packaging waste disposal fees; environment agency registration  fees and costs such as PRNs sit outside eco-modulation.

RAM ratings explained: How Red, Amber and Green packaging affect EPR fees

The system is straightforward once you know what each colour means.

Green packaging is highly recyclable. It receives a discount from the amber fee, so more recyclable formats are rewarded.

Amber packaging is recyclable but with limitations. It sits at the base fee, with no modulation adjustment either way.

Red packaging is not currently recyclable at scale. It pays a premium above the amber fee, so less recyclable formats cost more.

The important thing to understand is that RAM ratings are based on real-world UK waste facility capabilities, not on what is technically recyclable in theory. A material can be recyclable in principle but still land a red rating if the infrastructure to collect and process it at scale does not yet exist here.

RAM is also not fixed. PackUK has published a RAM roadmap, (through to 2030, with annual updates and technical reviews covering areas such as rigid plastics, printing inks, fibre-based composites and food contamination. Bioplastics and compostables are under review for possible inclusion from 2029. In short, a rating you are comfortable with today may need revisiting.  Our blog from XXX covered this.

Why non-recyclable packaging will increase your EPR fees

The premium on red-rated packaging does not stay still. It escalates over three years:

• 2026/27: red-rated packaging pays 1.2 times the amber disposal-fee element
• 2027/28: the multiplier rises to 1.6 times
• 2028/29: red-rated packaging reaches 2.0 times the amber rate

This escalation is deliberate. It gives businesses time to redesign difficult formats while making the financial case for change stronger each year. A format left unchanged through 2028 to 2029 could face a red disposal-fee element double its amber equivalent.

Green packaging works the other way. It receives a discount funded by the extra revenue collected from red-rated packaging. The scheme is designed to be revenue-neutral overall, so modulation redistributes liability between packaging types rather than raising total disposal fees across the market. That also means the green discount is not fixed in advance. It depends on the final mix of red and green packaging reported across the whole market.

Packaging EPR fee estimates for 2026/27: What costs could look like

PackUK has published illustrative figures. These are estimates and remain subject to change pending final data, but they give a sense of the scale. For 2026/27, the illustrative red premium is around 20% above amber, while the indicative green discount is about 9% below amber.

Material	Green  £/t	Amber  £/t	Red £/t
Aluminium	£245	£270	£325
Glass	£185	£205	£245
Paper and board	£190	£210	£250
Plastic	£415	£455	£545
Fibre-based composite	£475	£525	£630
Steel	£260	£290	£345
Wood	£410	£450	£540
Other	£205	£225	£270

Take plastic as an example. A business placing 100 tonnes of plastic household packaging on the market would face an illustrative £45,500 at the amber rate, £54,500 if it were red, or £41,500 if it were green. That is a £13,000 spread between the two ends of the rating scale, on a single material, in a single year. These figures are for illustration only. Final 2026/27 fees will depend on completed reporting and data assurance.

Medical packaging and EPR fees: Special rules explained

Medical packaging has a tailored treatment. It stays within modulation, but packaging that is red because legal or regulatory requirements prevent a more recyclable alternative may be reported as amber-medical, provided you can substantiate that status. Red medical packaging that is not constrained in this way is modulated like any other red packaging.

How to reduce future packaging EPR fees

The sensible response is to treat RAM as a product-design and procurement discipline, not just a compliance reporting exercise. A few practical steps will help you avoid unnecessary fees.

Review your packaging formats. Build a component-level inventory. Assess every packaging component, not just the primary pack, by material, format, weight, household status and RAM outcome.

Find your red hotspots. A low-volume red format may not justify immediate redesign. A high-tonnage red flexible pack, composite format or hard-to-sort component could carry a significant multi-year cost. Prioritise accordingly.

Speak to your suppliers. Ratings are self-reported, but regulators will check their accuracy. You will need traceable technical evidence, material specifications and clear decision records. Bring RAM into your supplier conversations and governance now, rather than scrambling for evidence later.

Design for real-world recyclability. The goal is not only lighter packaging. It is packaging that can genuinely be collected, sorted and recycled through the relevant UK system.

Watch out for unintended substitution. Switching away from one red format should be tested for whole-pack consequences, including barriers, labels, adhesives, closures, pigments, sleeves and secondary packaging. A quick fix on one component can create a new problem elsewhere.

Factor EPR costs into product decisions. Use a rolling cost model. With the fee multiplier climbing from 1.2 to 2.0, red exposure gets more expensive every year. Building that into procurement and product decisions now protects your margins later.

Reduce Your Packaging EPR Fees Before Costs Rise Further

Eco-modulation is designed to reward recyclable packaging and increase costs for formats that are difficult to collect, sort or recycle. As red-rated packaging premiums continue to rise over the coming years, businesses that act now will be in a stronger position to control costs, reduce compliance risks and protect margins.

Speak to a Packaging EPR Expert