UK pEPR fees for 2026-27: what the illustrative rates mean for producers

The UK's packaging Extended Producer Responsibility scheme (pEPR) now has two official sets of numbers in circulation, and they answer different questions. The 2025 base fees are final: they are what large producers are actually being invoiced for Year 1. The 2026-27 rates, published in December 2025, are explicitly illustrative: they show what Year 2 is likely to cost, split for the first time by recyclability, but they are not the rates that will appear on an invoice. Confusing the two is the fastest way to mis-budget a client. This guide sets out what each publication says, and what to do with it.

2025: the final base fees (Year 1)

The 2025 base fees are flat per-material rates on household packaging, with no recyclability modulation in Year 1: aluminium £266, fibre-based composite £461, glass £192, paper or board £196, plastic £423, steel £259, wood £280 and other materials £259 per tonne. One practical detail: the published figures are rounded to the nearest pound, while PackUK's actual invoicing uses rates to four decimal places — so a reconciliation against the published table will be close, not exact.

2026-27: illustrative rates, split by recyclability

The Year 2 illustrative disposal fees give three figures per material — green, amber and red — reflecting how the packaging scores under the Recyclability Assessment Methodology (RAM). Plastic, for example, is shown at £415 green, £455 amber and £545 red per tonne; wood moves most against Year 1, at £410/£450/£540. The word illustrative is doing real work in that title: these rates were published so producers could budget and see the direction of modulation, not to be invoiced against.

How RAM modulation escalates

The PackUK modulation statement fixes the mechanics. Amber is the neutral baseline — an amber rating means the base fee, unchanged by modulation. Red is a fixed and rising multiplier on amber: 1.2× in 2026-27, 1.6× in 2027-28, 2.0× by 2028-29. Green is not a fixed multiplier at all: the surplus collected from red packaging is redistributed as a uniform discount across all green tonnage, so the green rate depends on how much red packaging everyone else declares. The Year 2 illustrative figures assume a green discount of roughly 9 per cent, and the publication itself marks that as provisional.

The planning consequence is straightforward: a red rating on a high-tonnage material is about to get expensive on a published schedule. A producer with red-rated plastic packaging faces a 20 per cent surcharge in Year 2 and double fees by 2028-29 — which means recyclability redesign now has a price tag you can put in front of a client, per material, per year.

Final rates come later in 2026

As of mid-2026 the confirmed 2026-27 rates have not been published. PackUK has said it will publish final fees and issue Notices of Liability later this calendar year, and has re-opened 2025 packaging data for resubmission with a 1 September 2026 deadline — worth noting, because the resubmitted data feeds the fee base. Until the final rates land, the December 2025 illustrative table is the best official number that exists, and anything built on it should say so.

Who actually pays

Disposal fees fall on large producers: organisations with annual turnover of £2 million or more and more than 50 tonnes of packaging supplied or imported — both conditions together, not either. Smaller organisations above the lower thresholds report data but pay no disposal fees. The turnover-and-tonnage test is worth re-running for clients near the boundary each year, because crossing it changes the cost of the same packaging by hundreds of pounds per tonne.

What producers should do now

• Budget Year 2 on the amber column, and model the red column as the downside case for any material whose RAM rating is uncertain.
• Get RAM ratings assessed early — the rating, not the tonnage, is now the biggest controllable lever on the fee.
• Check the large-producer test for boundary clients before committing to a forecast.
• Treat every 2026-27 figure as an estimate until the Notice of Liability arrives — the illustrative table is for planning, and official invoicing prevails.

Complywerk's fee-estimate engine applies exactly this discipline: official 2025 rates carry an official badge, 2026-27 rates carry an explicit 'illustrative, not final' badge, and the RAM what-if lets you switch a client between red, amber and green to see the delta — always as an estimate, never as an invoice.

Figures above are from the gov.uk publications linked inline; check them against the originals before relying on them, and expect the final 2026-27 rates to supersede the illustrative table later in 2026. Contains public sector information licensed under the Open Government Licence v3.0.