The UK Packaging Invoice Now Punishes Bad Recycling
The next invoice has a new variable in it
Large UK packaging producers have had an annual bill since 2025: a Notice of Liability from PackUK, the body that administers packaging Extended Producer Responsibility (pEPR), covering what they put on the market the year before. The second one is due by the end of November, and it is the first where the fee itself depends on how recyclable that packaging actually was, not only on how much of it there was.
Who this actually reaches
pEPR only applies to “large producers”: businesses with turnover above £2 million that supply more than 50 tonnes of packaging into the UK market in a year. If you brand and ship your own product at that kind of volume, this invoice is yours, whether or not Amazon is the marketplace you sell through. It is also yours as the brand owner, not Amazon’s, if you hold your own UK packaging registration; sellers who route through someone else’s EPR registration should check whose name is actually on the liability before assuming it is covered. Below that line the obligation is lighter. Smaller producers still report packaging data, but are not currently charged the fee itself.
What changed: packaging now has a grade
From this cycle, fees are set under the Recyclability Assessment Methodology, which rates packaging red, amber or green. Illustrative 2026/27 base (“amber”) rates run from £205 a tonne for glass to £455 for plastic and £525 for fibre-based composite material, according to PackUK’s year-two illustrative fees. Red-rated packaging, meaning hard to recycle in practice and not just on paper, pays about a fifth more than that amber rate this year. Green-rated packaging gets roughly a 9% discount. The gap is built to widen: under PackUK’s modulation statement the red factor rises from 1.2 to 1.6 and then 2.0 by 2028/29, so a packaging choice that costs a little more now costs much more in three years.
PackUK still calls these figures illustrative and says they are likely to change once the 2025 data has been checked, so the number on the actual notice can differ. Its operational plan puts that notice at the end of November 2026, as a single notice with no scheme-wide recalculation afterwards. The notice itself sets out how and when to pay.
What to do before the next one
The tonnage behind this year’s bill is already fixed, since it is based on packaging that shipped in 2025; only the rate is still to be confirmed. The rating that determines next year’s bill is being set by what ships now. If you package your own product and have not checked which band your packaging falls into, that is the one concrete thing worth doing before the next reorder: ask your packaging supplier for its recyclability rating, or check the material against the published methodology, rather than finding out from the invoice.