Base fees for Extended Producer Responsibility released
PackUK has released guidance for the UK’s Extended Producer Responsibility for Packaging (pEPR) legislation.
Pack UK has confirmed the 2025 base fees ahead of the first invoices in October 2025, and nearly all fees have been reduced compared with the illustrative base fees published in December, with glass down by 20%.
PackUK says the reductions result from high levels of industry compliance, with reporting obligations and extensive work across the regulators and PackUK to assure and validate the data provided.
PackUK will hold a base fees themed webinar on Thursday 10 July 2025.
PackUK has also published the Producer Fee Modulation Policy Statement, which outlines how fees will be adjusted from 2026 onwards.
The new modulation policy establishes a three-year framework that will adjust producer fees based on 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 RAM green-rated (highly recyclable) packaging will benefit from steadily decreasing fees
- Producers of RAM Red-rated (poorly recyclable) packaging will face progressively higher fees
- Special provisions apply for medical packaging where regulatory requirements limit recyclability options
In response to industry feedback regarding the time and resource required to meet the 2025 recyclability assessment obligations, the four nations' environmental regulators have published a Regulatory Position Statement (in Wales, a Regulatory Decision) providing additional flexibility for producers during transition.
This aims to ease the burden while maintaining the commitment to introduce modulated pEPR fees from the 2026–27 assessment year.
While producers must still report tonnages for the first half of 2025 including flexible and rigid plastics separately, the recyclability assessment obligations for this period can be extrapolated from second-half data.
In setting up the pEPR scheme, PackUK, as Scheme Administrator, is required to publish an interim strategy, which has been approved by officials from all four nations and devolved ministers in parallel for agreement.
A long-term strategy will be launched later in 2025 to include:
- Long-term structures and arrangements (imminent appointments of Chief Executive Officer and Chief Strategy Officer).
- Developments to UK-wide policy objectives over the coming months e.g. work in reuse, the Local Government Outcomes Framework for England.
- Planned appointment of a Producer Responsibility Organisation by March 2026.
