ERP Extended Producer Responsibility

EPR Fees: Is Your Packaging Hurting Your Bottom Line?

Jun 12, 2026by Delon Biton
Extended Producer Responsibility

If you run a takeaway or catering operation in the UK, you have probably come across the phrase Extended Producer Responsibility, or EPR, in the past year or so. Maybe a supplier mentioned it, maybe you spotted it in an industry newsletter, or maybe your accountant flagged it as something to keep an eye on. Whatever the case, if you have not yet looked at how EPR fees relate to your specific packaging choices, now is the time to pay attention.

Since January 2025, EPR regulations have required packaging producers to cover the full net cost of managing household packaging waste - a significant shift from the previous system where producers funded only around 10% of those costs. The first invoices landed in October 2025. And from April 2026, the scheme gets more consequential: fees are now modulated by recyclability, meaning businesses using hard-to-recycle packaging materials are, in practical terms, paying a premium that more sustainable operators are not.

This blog explains what EPR is, how the fee structure works, which materials attract higher or lower costs under the new system, and what switching to widely recyclable alternatives, such as Albiz's NextGen HMS-PP range, could mean for your bottom line.

Extended Producer Responsibility is a UK-wide regulatory framework

What Is EPR and Why Does It Matter for Takeaways?

Extended Producer Responsibility is a UK-wide regulatory framework that makes the businesses responsible for placing packaging on the market, including food packaging, pay the full cost of managing that packaging once consumers dispose of it. That includes collection, sorting, recycling, and where necessary, disposal.

The scheme is administered by PackUK and operates across all four UK nations. It replaces the old Packaging Recovery Note (PRN) system, which was widely criticised for funding only a fraction of the actual costs and allowing much of the UK's plastic waste to be exported rather than recycled domestically.

For takeaway and catering businesses, EPR is relevant for two reasons. First, you may be directly liable, either for reporting obligations or for paying disposal fees, depending on your turnover and packaging volumes. Second, even if you fall below the direct liability thresholds today, your packaging suppliers are liable, and those costs are beginning to filter through supply chains as surcharges and price adjustments.

In short: the packaging decisions you make now have a real cost consequence, and that consequence is set to increase.

Government's packaging EPR

Who Is Liable Under EPR?

EPR obligations are split between large and small producers:

  • Large producers (businesses with annual turnover above £2 million that supply or import more than 50 tonnes of packaging per year) must register, report packaging data twice yearly, purchase Packaging Recovery Notes, and pay waste disposal fees.

  • Small producers (businesses with turnover above £1 million that handle between 25 and 50 tonnes) must register and report data, but do not currently pay the full disposal fees.

  • Businesses below these thresholds are not directly obligated under EPR, though they may still be indirectly affected through supplier pricing.

If you are unsure whether your business is in scope, the UK Government's packaging EPR guidance on GOV.UK is the authoritative reference point. What is clear is that ignorance of the thresholds is not a defence, and as the scheme matures, enforcement and data accuracy requirements will only tighten.

 

How the Fee Structure Works: Base Fees and Modulation

Year 1 (2025/26): Flat Base Fees by Material

In the first year of EPR (2025/26), all packaging within a material category pays the same flat rate regardless of how recyclable it actually is. The confirmed 2025/26 base fees are:

  • Plastic: £423 per tonne

  • Paper and cardboard: £196 per tonne

  • Glass: £192 per tonne

  • Steel: £178 per tonne

  • Aluminium: £375 per tonne

These fees are charged based on the weight of packaging placed on the market, so a business using large volumes of heavier plastics or composite materials will carry a proportionally higher cost burden.

Year 2 (2026/27): Recyclability-Modulated Fees Kick In

From April 2026, the fees changed. PackUK introduced the Recyclability Assessment Methodology (RAM), which rates every packaging format against a Red-Amber-Green (RAG) system across five stages: classification, kerbside collection, sortation, reprocessing, and end market viability. A single red result at any stage produces an overall red rating for that packaging format.

The financial impact of that rating is significant:

  • Red (hard to recycle): base fee × 1.2 - a 20% cost uplift

  • Amber (standard): base fee × 1.0 - the baseline rate

  • Green (widely recyclable): approximately base fee × 0.9 - around a 10% discount

For plastic, the illustrative 2026/27 amber base fee rises to £455 per tonne. That means red-rated plastic packaging costs approximately £545 per tonne, a £130 per tonne differential versus green-rated equivalents. And the penalty is set to increase: the multiplier rises to 1.6× in 2027/28 and is expected to reach 2.0× by 2028/29.

There is also an important data trap: any missing or incomplete RAM data automatically defaults to a Red rating. Businesses that have not yet gathered their packaging assessment data are, in effect, already accruing the highest possible fee exposure for their next billing period.

Which Packaging Materials Attract Higher Fees

Which Packaging Materials Attract Higher Fees?

For UK takeaway operators, the materials to watch most closely are those most likely to attract Red RAM ratings:

XPS and EPS (Expanded/Extruded Polystyrene)

XPS and EPS containers, still widely used in some takeaway and catering operations for portion boxes and fish trays, are among the most problematic formats under the RAM. Neither material is kerbside-collected at the required scale (75% of UK local authorities), and both face significant challenges at the sortation and reprocessing stages. Under current RAM guidance, polystyrene formats are expected to receive Red ratings, making them the most expensive option in fee terms going forward.

XPS has also faced growing regulatory pressure on environmental grounds for several years. Operators still relying on it should factor in not just the EPR premium, but the likely direction of travel.

Multi-Layer and Composite Plastics

Multi-material trays, such as those combining PET with CPET, or plastic with foil seals and non-separable components, are a particularly difficult category under the RAM. The RAM assesses each component, and a single failing stage results in a Red rating overall. Composite packaging that cannot be separated at household level for kerbside collection is very likely to attract the Red premium.

Around 45% of plastic packaging currently placed on the UK market is reported to fail recyclability criteria under the RAM. For food operators reviewing their container range, this is a significant data point.

Bagasse Containers

Bagasse is often marketed as an eco-friendly choice, and it is compostable, but compostability and recyclability are not the same thing under the RAM. Bagasse is classified as industrial compostable, meaning it requires specialist facilities rather than household kerbside collection. Under the RAM, this is likely to result in a Red rating for household packaging purposes. Operators who switched to bagasse for sustainability reasons should note that the EPR fee structure does not currently reward compostability as a recyclability proxy.

There is a further operational concern: bagasse absorbs significantly more moisture than mono-material plastic - independent testing puts it at over three times the moisture absorption of HMS-PP. For hot or oily food, that means a higher rate of leaks, soggy bases, and customer complaints.

Which Packaging Materials Attract Lower Fees

 

Which Materials Attract Lower Fees?

Mono-Material Polypropylene (PP)

Polypropylene is a mono-material plastic that is kerbside-collected by the majority of UK local authorities and has established end markets for recycled PP. Well-designed PP containers, particularly those that are uncoloured or lightly coloured, free from non-PP components, and designed for easy identification by near-infrared sorting equipment, have a strong basis for Amber or Green RAM ratings under current guidance.

This is the material at the core of Albiz's NextGen HMS-PP range. HMS-PP (High Melt Strength Polypropylene) is a food-grade, mono-material PP with near-zero moisture absorption, strong oil resistance, and reliable heat retention. It is microwave-safe, leakproof, and lighter than bagasse or carton board - which can reduce shipping costs at scale.

Uncontaminated Cardboard and Paper

Paper and cardboard remain a cost-effective option under EPR, with a base fee of £196 per tonne in Year 1, less than half the plastic rate. Cardboard that is uncontaminated, mono-material, and kerbside-collected is well-positioned for Green or Amber RAM ratings. However, cardboard with wax coatings, plastic linings, or heavy grease contamination can fail at the reprocessing stage and attract Red ratings, so not all cardboard is created equal in EPR terms.

For pizza boxes and dry food cartons, well-specified cardboard packaging remains a sound choice from an EPR cost perspective, particularly when it meets food contact standards without the need for non-recyclable coatings.

 

At a Glance: How Common Takeaway Packaging Compares

The table below summarises how the most common takeaway packaging materials stack up across the key EPR and operational dimensions. RAM ratings shown are indicative based on current published guidance and may vary depending on specific product design and data submitted.

How Common Takeaway Packaging Compares
Switching to Recyclable Packaging

What Switching to Recyclable Packaging Looks Like in Practice

Switching packaging is not just a compliance exercise, it is a commercial one. Operators moving from XPS or multi-layer plastic to mono-material PP can expect to reduce their EPR fee exposure (Red premium avoided), reduce complaint rates from leaking or soggy containers, and achieve better heat retention through to the customer, which directly supports delivery satisfaction.

Albiz stocks a range of NextGen HMS-PP containers designed specifically for UK foodservice. Available in bulk with same-day dispatch when ordered by 12:30pm. The full NextGen range includes:

All NextGen HMS-PP containers are mono-material, widely recyclable, microwave-safe, and leakproof. Built for the operational demands of busy UK takeaways and catering businesses.

Browse the full NextGen range at Albiz Packaging: https://albizpackaging.co.uk/search?q=next+gen&options%5Bprefix%5D=last 

 

The Bottom Line

EPR is not a future concern, it is a present one. First invoices went out in October 2025. Modulated fees based on recyclability apply from April 2026. And the penalty for hard-to-recycle packaging is set to escalate significantly through 2027 and 2028.

For takeaway and catering operators, the practical response is straightforward: review your packaging against the RAM criteria, identify any formats likely to attract Red ratings, and where possible, switch to mono-material widely recyclable alternatives. Not just because it reduces your EPR exposure, but because it also tends to deliver better operational performance and lower complaint rates.

Albiz Packaging is here to help. If you want to discuss your packaging range, get bulk pricing on NextGen HMS-PP containers, or simply find out more about which products in our range are best positioned for EPR compliance, get in touch with our team.

https://albizpackaging.co.uk/ 

FAQs

Does EPR apply to my takeaway?

If your business has a turnover above £1 million and handles over 25 tonnes of packaging annually, you must report. If turnover exceeds £2 million and packaging exceeds 50 tonnes, full disposal fees apply. Even if you fall below these thresholds today, switching to recyclable packaging is a low-risk way to future-proof your costs.

What does RAM stand for?

Recyclability Assessment Methodology. It is the scoring system used by PackUK to assign packaging a Red, Amber, or Green rating. That rating then directly determines the EPR disposal fee multiplier applied to your packaging tonnage.

Is HMS-PP considered recyclable under the RAM? 

PP (polypropylene) is a mono-material that is kerbside-collected by the majority of UK local authorities and can be reprocessed into secondary material. Based on current RAM guidance, well-designed PP containers have a strong basis for an Amber or Green rating. Always verify the specific product with your compliance adviser.

Are XPS and EPS containers now banned? 

Not banned outright, but they attract Red RAM ratings and the corresponding 20% fee premium in 2026/27, rising to a 60% uplift in 2027/28 and potentially doubling fees by 2028/29. They are also subject to growing retail and consumer pressure.

What if I do not have complete RAM data? 

Missing or incomplete data automatically defaults to a Red rating, which means you will pay the highest possible fee. Accurate reporting is essential. Contact your packaging supplier or a compliance scheme for support.

 
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