Pricing Responsibility: What EPR’s 2025 Base Fees Mean for the Industry

The arrival of base fees under the UK’s Extended Producer Responsibility (EPR) scheme for packaging signals a quiet but consequential shift in how we think about — and pay for — the materials we place on the market. After years of policy development, consultation, and modelling, PackUK has now published the figures that will anchor the first year of EPR’s cost structure. For anyone working in waste management, recycling, compliance, or packaging production, this is not just regulatory fine print — it’s the shape of things to come.

A New Economic Layer for Packaging Waste

From 2025 to 2026, producers of packaging that ends up in household waste streams will pay fees designed to recover the costs borne by local authorities for collecting, sorting, and disposing of that packaging. These fees, set and managed by PackUK, are calculated per tonne and vary by material.

The rates range from £192 per tonne for glass to £461 for fibre-based composites. Plastic lands at £423, while aluminium — perhaps surprisingly — sits lower at £266. The complete schedule covers eight categories, including a catch-all ‘Other’ group priced at £259 per tonne, encompassing materials such as rubber, cork, and bamboo.

These aren’t market prices or taxes. They’re a reflection of cost modelling: what it takes for councils to handle packaging once it becomes waste, minus the income they can recoup from selling the materials. But they’re also, subtly, an attempt to embed responsibility deeper into the system — to align the economics of packaging with the realities of its disposal.

Calculating the Cost of End-of-Life

The methodology behind these fees is intentionally transparent. For each material, the base fee is calculated by dividing the net cost to local authorities (adjusted for material sales and including administrative, communication, and bad debt provisions) by the total weight of relevant packaging placed on the market.

Importantly, that denominator includes not only household packaging but also items typically disposed of in public bins or as litter. This means producers are paying into a system that accounts for public realm waste, even if the numerator — the cost side — has yet to fully reflect those collection challenges. That addition is expected in future iterations, suggesting a fee trajectory that may trend upward over time.

Free-Riders and Data Adjustments

Data underpinning the fee calculations comes from the Report Packaging Data (RPD) portal. But not all producers submit their figures on time — or at all. To address this, PackUK has made several adjustments to ensure the reported tonnages reflect something close to reality.

Late reporters’ data has been scaled up based on patterns from previous years. For those entirely missing — the so-called ‘free-riders’ — estimations have been modelled using average tonnes per producer, adjusted by nation and by reporting behaviour. Some data has been excluded entirely where quality couldn’t be assured, particularly for direct registrants whose submissions had been rejected.

This effort to “close the gap” is more than statistical tidying. It speaks to the broader challenge of implementation: ensuring that the financial burden of compliance is fairly distributed and that early adopters aren’t penalised for their diligence while others delay or avoid reporting.

Local Authority Costs and LAPCAP

At the heart of the base fee calculation lies LAPCAP — the Local Authority Packaging Cost and Performance model. Developed by Defra, this tool combines localised data (from sources like Waste Data Flow) with comparative benchmarks to estimate what it really costs councils to handle packaging waste.

For local authorities, this is potentially transformative. EPR promises not just more funding, but more accurate payments — tailored to performance, geography, and material streams. For the wider industry, it means that the money producers pay is going somewhere tangible: to the systems that deal with the consequences of packaging design decisions.

Looking Ahead to Modulated Fees

The base fees published this year are just the beginning. From 2026, they will be replaced — or rather reshaped — by modulated fees that adjust according to how recyclable a material is.

This modulation will be determined by the Recyclability Assessment Methodology (RAM), which assigns red, amber, or green ratings to packaging types. Red-rated packaging will carry higher fees, intended to fund reductions for green-rated materials. Amber remains neutral.

This signals a policy move from cost recovery to behaviour change — not just paying for the damage, but rewarding better design. But such a system relies on agreement over what counts as recyclable, how performance is measured, and whether infrastructure exists to support that recyclability at scale. There are clear tensions here between design intent and real-world outcomes, and these will no doubt evolve as the scheme matures.

What Happens Next

Producers are expected to report their packaging data for January to June 2025 by 1 October 2025. Invoices, based on that data and the base fee structure, will follow shortly after. Meanwhile, further guidance on modulation and recyclability ratings is expected in the coming months.

PackUK has also indicated that payments to local authorities, based on LAPCAP modelling, will be published soon — along with an explanation of how those figures were derived.

Let’s Recycle It’s Perspective

Let’s Recycle It welcomes the principle that those who put packaging into circulation should play a meaningful role in financing its end-of-life. Creating a packaging economy that accounts for environmental impact is not just a matter of fairness — it’s a necessity for building systems that work.

At the same time, regulations must be coherent, workable, and rooted in operational reality. Good intentions can falter if schemes are over-complicated, poorly timed, or detached from the practicalities of collection, sorting, and reprocessing.

The company supports legislation that not only compels recycling, but also mandates the use of recycled content — creating both supply-side pressure and downstream demand. But this support is qualified by a call for thoughtful design: frameworks that are phased, flexible, and informed by those who know the materials best.

Let’s Recycle It continues to contribute to the conversation — not because the system is perfect, but because it must be made better. And that, as ever, is a collective task.