Intro: The UK has been invoicing companies for the packaging they put on its market since October 2025 — flat fees per tonne, by material, with no reward yet for choosing recyclable packaging over hard-to-recycle packaging. That changes with the 2026-27 fee year, and the number that matters has moved from "illustrative" to confirmed policy: hard-to-recycle packaging now pays a 1.2× multiplier on the base fee this year, rising to 1.6× next year and 2.0× the year after. A packaging choice made at setup doesn't just cost more once you scale past the large-producer threshold — it costs progressively more every year you keep using it.
What's been running since October 2025
The UK's packaging Extended Producer Responsibility scheme makes the business that places packaged goods on the UK market pay toward the cost of handling that packaging as waste. The first fee year ran on flat base fees per tonne, by material, with no adjustment for how recyclable the packaging actually is: plastic at £423 a tonne, more than double paper and card at £196 or glass at £192. Liability sits with whoever imports packaged goods into the UK and sells them, or owns the brand — below £1 million turnover or 25 tonnes of packaging a year there's no obligation at all; between £1m and £2m turnover and 25–50 tonnes you register and report but don't pay the disposal fee; only past £2 million and 50 tonnes do the per-tonne fees actually land.
What's confirmed now that wasn't confirmed in June
From the 2026-27 fee year, disposal fees are modulated against a Red-Amber-Green recyclability rating, and the multiplier schedule is now settled policy rather than an illustrative projection: Red-rated — the least recyclable — packaging pays 1.2× the base fee this year, rising to 1.6× in 2027-28 and 2.0× in 2028-29. Amber-rated packaging sits at the base fee itself, and Green-rated packaging earns a discount below it. The escalation is deliberate and already scheduled three years out — a packaging format that's merely inconvenient to pay for today is on a fixed path to genuinely expensive.
The funds raised from the Red multiplier are explicitly redistributed toward Green-rated packaging's discount — this isn't a flat surcharge sitting alongside the base scheme, it's a transfer mechanism built to reward the recyclable choice at the direct expense of the hard-to-recycle one, and it gets more pronounced every year rather than settling at a fixed gap.
The three-year schedule, now confirmed rather than provisional:
| Fee year | Red-rated multiplier | Amber-rated | Green-rated |
|---|---|---|---|
| 2025–26 (first year) | Flat fee — no modulation | Flat fee | Flat fee |
| 2026–27 | 1.2× base fee | Base fee | Discounted below base |
| 2027–28 | 1.6× base fee | Base fee | Discounted below base |
| 2028–29 | 2.0× base fee | Base fee | Discounted below base |
Why this lands differently for a brand setting up now versus one already scaled
A brand launching into the UK this year is very likely below the large-producer threshold and isn't writing a disposal-fee cheque at all yet — that part of the picture hasn't changed. What has changed is the cost of the packaging decision itself. A format chosen at setup because it was cheaper or more available in India follows the brand through every fee year it scales into, and under the confirmed schedule a Red-rated choice isn't just costlier once — it's costlier by a widening margin every year for at least three years running. Designing for recyclability at setup is now a three-year-compounding decision, not a one-off cost trade-off.
Run the multiplier against the confirmed 2025 base fees and the compounding is concrete, not abstract. A brand shipping 10 tonnes a year of Red-rated plastic packaging — at the 2025 base of £423 a tonne — is looking at roughly £4,230 in 2025-26 with no modulation applied. Run the same 10 tonnes through the confirmed 2026-27 multiplier at 1.2× and the fee is already £5,076; by 2028-29 at 2.0× it's £8,460, roughly double the 2025-26 figure, on the same packaging choice and the same volume. A Green-rated alternative on the same volume moves in the opposite direction over the same three years. Nothing about the underlying business changed — only which RAM rating the packaging carries.
The labelling mandate that got quietly delayed
One thing worth knowing precisely, because the direction of travel is easy to misread: mandatory on-pack recyclability labelling was originally planned to land alongside pEPR, then removed from the main statutory instrument in late 2024 specifically to avoid delaying the fee scheme itself. It is not currently enforced, and Defra has said it will revisit UK mandatory labelling once the EU's own approach is clearer, expected around summer 2026. That's a delay, not a cancellation — 2027 remains the planning horizon most of the industry is working to, and a brand that adopts RAM-aligned recyclability labelling voluntarily now avoids a reprinting exercise whenever the mandate does land, rather than treating the delay as permission to ignore it.
Worth settling before your first UK shipment
- Work out which producer bracket you land in, and, separately, when growth is likely to push you past the large-producer threshold — the modulation schedule matters most for brands about to cross it, not ones comfortably below it.
- Get your packaging's RAM rating checked now, not once fees start landing — a Red rating discovered after the packaging is already locked in and printed is a far more expensive fix than choosing differently at setup.
- Cost the per-tonne fee against the materials you actually use, run against all three confirmed years, not a single blended average or the flat 2025 figure alone.
- Check that whoever imports and sells your goods in the UK is registered and reporting, since liability follows the importer of record or brand owner, not just the manufacturer back in India.
A Red-rated packaging choice isn't a fixed cost anymore — it's on a schedule that doubles by 2028-29, and the schedule is confirmed, not a projection.
None of this is a reason to over-engineer packaging for a brand that's still below the large-producer threshold — the fee liability genuinely doesn't land yet. It is a reason to make the packaging call with the full three-year schedule in view rather than against only the flat 2025 numbers, especially for a brand that expects to scale past £2 million and 50 tonnes inside that window, or one already weighing packaging and duty costs together against a CETA-eligible landed-cost calculation. We build UK compliance costing into onboarding alongside VAT registration, so packaging decisions get made against the schedule that actually applies, not the one that was true a year before launch.