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EPR Year 1 Invoicing: What You Need to Know

A summary of the government guidelines on invoicing and payments for the year ahead.

In October 2025, obligated producers under the UK’s Extended Producer Responsibility for packaging (pEPR) scheme will be issued their first invoices for the assessment year (1st April 2025 to 31st March 2026), with each producer’s share of disposal costs calculated using their 2024 packaging data.

Read on for a summary of the core information and action required from producers.

 

Overview

  • The upcoming invoice will be referred to as a ‘Notice of Liability’ (NoL).
  • The amount invoiced will be based on the data you submitted for 2024, compared with the data from all known producers.
  • Fees may be updated later in the year if data is resubmitted or corrected and this substantially changes obligations.
  • All fees collected will be passed to local authorities to help cover the cost of managing household packaging waste.
  • Failure to pay may lead to enforcement action.

 

How fees are calculated

Your invoice will include:

  • Disposal fees for household packaging (based on 2024 data)
  • Scheme administration costs
  • Public information disposal costs
  • A provision for bad debt

 

How to access your invoice

  • Invoices will be available in the Report Packaging Data (RPD) service from October.
  • PackUK will notify Primary Contacts and Approved Users when they are ready.
  • Only RPD users can access and download the invoice.
  • Additional people (such as finance personnel) can be added to the account by an Approved User.
  • PackUK customer service will only be able to discuss account details with Primary Contacts and Approved Users.
  • We recommend logging in to the RPD system before October to check details are correct.

 

Payment of fees

  • Pay in full within 50 days, or opt for the four-instalment plan (via Stripe).
  • Accepted methods: Direct Debit, bank transfer to your VBAN, credit card or standing order.
  • All fees collected will be passed to local authorities to help cover the costs of managing household packaging waste.
  • Failure to pay may lead to penalty charges and legal action.
  • Late payment may trigger penalties: either 20% of unpaid fees, or 5% of UK turnover (for a single entity) / 2% (for a group) — whichever is greater.

 

Changes to invoices

  • If you make significant resubmissions that alter your obligation, you may receive an updated invoice later in the year.
  • Not all producers will be re-invoiced; only those whose data has changed in a way that materially affects costs.
  • Any end-of-year adjustments will be clearly communicated by PackUK.

 

Next steps:

  1. Check that your organisation’s RPD account contact details and email addresses are up to date.
  2. Add finance personnel requiring payment administration access to the account.
  3. Plan ahead for October invoices by confirming internal payment processes and responsibilities.
  4. Review submitted 2024 tonnages and calculate estimated fees using published material rates.
  5. Prepare internal processes for statutory debt payment without traditional supplier documentation.
  6. Watch for communications from PackUK to avoid missing deadlines.

 

Need support? Contact your Clarity account team for a readiness check ahead of invoicing.