UK Packaging EPR Fees Just Got Modulated: What Food Brands Exporting to Britain Need to Know
Updated April 2026. Year-2 pEPR fees confirmed, with recyclability-based modulation now active.
The UK’s Extended Producer Responsibility for packaging (pEPR) has entered its second year with a major change: fees are no longer flat rates. Starting in the 2026/27 fee cycle, packaging materials are rated Red, Amber, or Green based on the Recyclability Assessment Methodology, and fees are modulated accordingly. Red-rated packaging (poor recyclability) pays approximately 20% above the base rate. Green-rated packaging (high recyclability) earns approximately 9% discounts. For food brands selling into the UK market, this means packaging material choices now directly affect your bottom line.
How the Fee System Works
Under pEPR, any business that handles packaging and meets turnover and tonnage thresholds must pay fees to fund the collection and recycling of that packaging. The total fee recovery target for Year 2 is approximately £1.56 billion — up from £1.44 billion in Year 1. Fees are calculated based on the weight of packaging placed on the UK market, multiplied by the material-specific base rate, multiplied by the recyclability modulation factor.
A newly appointed UK Packaging PRO (Producer Responsibility Organisation) now manages scheme operations, replacing the previous compliance-scheme model. The transition took effect April 2026.
What the Modulation Factors Mean for Food Packaging
| Packaging Type | Likely Rating | Fee Impact |
|---|---|---|
| Uncoated kraft paper bags | Green | ~9% discount on base rate |
| Corrugated cardboard boxes | Green | ~9% discount |
| Clear PET containers | Green/Amber | Discount to neutral |
| PP containers (single material) | Amber | Base rate (neutral) |
| Multi-material laminates | Red | ~20% surcharge |
| Black plastic (carbon black) | Red | ~20% surcharge |
| Non-recyclable flexible film | Red | ~20% surcharge |
| Compostable PLA (no recycling stream) | Red/Amber | Surcharge to neutral |
The modulation multipliers will escalate over three years: approximately 1.2× for red-rated packaging in 2026/27, rising to 1.6× in 2027/28 and 2.0× in 2028/29. This means the financial penalty for using hard-to-recycle packaging doubles within three years.
The UK Plastic Packaging Tax
In addition to pEPR fees, the UK Plastic Packaging Tax applies to plastic packaging manufactured in or imported into the UK that contains less than 30% recycled plastic content. The tax rate increased to £228.82 per tonne from April 1, 2026. This means plastic food containers with less than 30% recycled content face both the tax and pEPR fees — a double cost incentive to switch to recycled or non-plastic materials.
What This Means for Food Packaging Decisions
Paper and cardboard win on fees. Uncoated kraft and corrugated packaging consistently rates Green, earning the maximum fee discount. For food brands selling takeaway packaging in the UK, paper-based solutions have a direct cost advantage beyond just material pricing.
Mono-material designs beat multi-material. A PP container with a PP lid is rated higher than a PP container with a PE-coated cardboard sleeve, because the latter is harder to separate for recycling. Simplifying your packaging materials reduces fees.
PLA is in a gray zone. Compostable PLA packaging has no established recycling stream in the UK and can contaminate PET recycling. Under the Recyclability Assessment Methodology, PLA may receive Amber or Red ratings despite being bio-based and compostable. This is a significant consideration for brands that adopted PLA specifically for UK sustainability positioning.
Key Dates for UK Compliance
The April 1, 2026 reporting deadline for Year 1 (2025) packaging data has passed. Year-2 fee invoices arrive in June 2026. The UK Deposit Return Scheme for beverage containers opens producer registration in Q3 2026, with DRS launch set for October 1, 2027. Businesses should begin assessing packaging portfolios against the Recyclability Assessment Methodology now to minimize Year-2 fee exposure.
Selling food packaging into the UK? GQ TH Pack supplies mono-material, recyclable-design food packaging that rates Green under UK pEPR — kraft bags, corrugated boxes, clear PET containers, and PP mono-material systems. Contact us for packaging that minimizes your UK EPR fees.