Final 2025 pEPR Fees and Fee Modulation Framework Announced

With the first Extended Producer Responsibility (pEPR) invoices due in October, the UK Government and Scheme Administrator, PackUK, have confirmed the final 2025 base fees and set out a new framework for future recyclability-based modulation.

The announcements – delivered on 27 June 2025 – mark a pivotal moment in the UK’s packaging reforms. They offer long-awaited financial certainty to obligated producers and introduce a three-year plan to incentivise the use of more recyclable packaging materials.

Following three iterations of draft figures, the final 2025 disposal fees for pEPR have now been confirmed. These figures are based on 2024 packaging data submitted by producers, combined with verified waste management costs from local authorities.

The table below compares the finalised fees with the third set of illustrative disposal fees published in December 2024, revealing that most material categories have seen a reduction—with glass fees falling by 20% being the most notable change.

These reductions reflect high levels of industry compliance with reporting requirements, alongside extensive assurance and validation work undertaken by PackUK and the four environmental regulators.

The finalised fees provide producers with the financial certainty they need as they prepare for the implementation of their pEPR obligations later this year.

Alongside the confirmed base fees, PackUK has also published the Producer Fee Modulation Policy Statement, setting out how disposal fees will be adjusted from 2026 onwards to encourage the use of more recyclable packaging.

The new modulation policy establishes a clear three-year framework that links producer fees to packaging recyclability, as assessed through the Recyclability Assessment Methodology (RAM) ratings. Starting from the 2026/27 financial year, the policy will apply escalating modulation factors of 1.2x, 1.6x, and 2.0x over consecutive years.

What this means in practice:

• Producers of Green-rated (highly recyclable) packaging will benefit from reduced fees.
• Producers of Red-rated (poorly recyclable) packaging will face progressively higher charges.
• Special provisions apply to medical packaging, where recyclability is limited by regulatory requirements.

This modulation approach is designed to maintain overall revenue levels while introducing meaningful financial incentives for producers to improve the recyclability of their packaging. By setting out a phased, long-term plan, the policy gives industry the certainty needed to make strategic investments in sustainable packaging and operational change.

Modulated fees will take effect from the second year of the scheme, applying to 2026–2027 financial year invoices, which are based on 2025 packaging data.

The table below demonstrates how the modulation factor for Red RAM packaging materials impacts disposal fees.

In response to industry concerns about the time and resources required to complete recyclability assessments in 2025, the UK’s environmental regulators have issued a Regulatory Position Statement (or a Regulatory Decision in Wales) to provide temporary flexibility for producers during this transition year.

Under this interim arrangement:

• Producers are still required to report packaging tonnages for H1 2025, including separate figures for flexible and rigid plastics.
• However, their recyclability assessments for this period can may be extrapolated from second-half data, easing the administrative burden during the rollout phase.

This transitional support helps producers comply without delaying the implementation of recyclability-based fee modulation in 2026.

Looking ahead, PackUK has also committed to reviewing how modulation might incorporate additional sustainability factors – such as carbon impact or reuse – after 2028.

In addition to fees and modulation, other key developments were announced:

• Dual-Use Packaging Definition Review: Further engagement is planned to address concerns about business-use packaging being unfairly classified as household waste under pEPR.
• Reuse Strategy: Recent research from GoUnPackaged highlights that a shift to 30% reuse in grocery retail could save £136m annually in pEPR fees and up to £577m overall. Reusable packaging will only incur pEPR fees once, regardless of repeat use.
• Producer Responsibility Organisation (PRO): The formal process to appoint the UK’s PRO will begin in October 2025, with an appointment expected by March 2026.
• Levelling the Playing Field: From January 2026, strengthened export accreditation requirements for PERNs will support UK-based recyclers and reduce reliance on exports.
• Local Authority Accountability: When local authority payment allocations are confirmed in July, PackUK will issue formal guidance to ensure EPR funds are strictly used for managing household packaging waste. In England, misuse of funds could result in deductions from the following year’s allocation.

More information can be found here.

These announcements represent a pivotal moment in the delivery of EPR reform in the UK. With confirmed fees, a clear path to recyclability-based modulation, and interim flexibility for 2025 assessments, producers can now plan with greater certainty

The regulatory landscape is now clearer:

• Final fees are set for 2025
• RAM assessments are streamlined for the transition year
• A firm timeline is in place for modulation to begin in 2026

For obligated businesses, the pressure is mounting to improve data accuracy, prepare recyclability assessments, and adapt packaging strategies in line with RAM classifications.