pEPR has moved from a future obligation to a live cost on this year's invoices. Here is a plain timeline of what has already happened, what is due next, and where the scheme is still developing.pEPR has moved from a future obligation to a live cost on this year's invoices. Here is a plain timeline of what has already happened, what is due next, and where the scheme is still developing.
Extended Producer Responsibility for packaging, known as pEPR, shifts the cost of managing household packaging waste from local councils onto the businesses that place that packaging on the UK market. The scheme has been live since April 2025, the first invoices have gone out, and several further reporting deadlines fall due before the end of 2026. This is a plain English guide to where things stand and what food and drink businesses need to do next.
What pEPR actually does and who it affects
pEPR moves the cost of household packaging waste collection and disposal away from council tax payers and onto the producers who put that packaging on the market in the first place. Fees are based on the type and weight of packaging a business places on the UK market each year, and the scheme is administered by PackUK on behalf of all four UK nations.
A large producer is a business with annual turnover of £2 million or more that supplies or imports more than 50 tonnes of packaging into the UK in a year. A small producer is generally a business with turnover between £1 million and £2 million that supplies more than 25 tonnes of packaging, or a business with turnover above £1 million supplying between 25 and 50 tonnes. Both conditions, the turnover test and the tonnage test, must be met for a business to be obligated. Falling below either threshold means the business is not currently in scope.
Where the scheme stands right now
The current scheme year runs from 1 April 2025 to 31 March 2026. Producers in scope began receiving their first official invoices, called Notices of Liability, from October 2025, covering that period and calculated from packaging data submitted for 2024.
Fees for this first scheme year are flat base rates per tonne of material. The published base fee for plastic packaging is £423 per tonne, against £192 per tonne for glass. PackUK confirmed there would be no change to these year one fees even after more accurate data identified a funding shortfall against original forecasts.
Notices of Liability are classed as statutory debt. Payment must be made in full within 50 days of the invoice date, or through a four instalment plan set up in advance. The late payment penalty is whichever is greater of 20 per cent of the unpaid fees, 5 per cent of UK turnover for a single registered organisation, or 2 per cent of UK group turnover where a business is registered as a group. This is a significant penalty and any business that has not yet engaged with its first invoice should treat this as a priority.
Key deadlines before the end of 2026
1 April 2026: large producers must report their packaging data covering July to December 2025. Small producers must report their full 2025 annual data by the same date.
From the 2026 to 2027 scheme year: fees move from flat base rates to a red, amber and green system based on the Recyclability Assessment Methodology. Packaging rated green for recyclability attracts a lower fee. Packaging rated red costs more. This is the point at which packaging design decisions start to have a direct, calculable effect on your EPR bill rather than only an environmental one.
1 October 2026: large producers must register and report their data covering January to June 2026, including for the first time mandatory self managed organisation waste data for businesses that collect and recycle their own packaging through closed loop arrangements.
PackUK appointed UK Packaging PRO as the scheme's Producer Responsibility Organisation, confirmed by March 2026. This organisation now acts as the central point of contact for data submission, fee calculation and compliance support. Businesses should confirm their registration status directly with UK Packaging PRO rather than assume it carried over automatically from an earlier stage of the scheme.
Why packaging design decisions now affect your EPR bill
The move to a recyclability based fee structure from the 2026 to 2027 scheme year is the development most worth flagging to anyone in packaging design or procurement, not only to finance teams. Once fees are tied to recyclability rather than weight alone, switching to a more recyclable format or a lighter weight design has a direct line to a lower EPR bill the following year.
PackUK has signalled further updates to the Recyclability Assessment Methodology are expected through 2026 and beyond, with a roadmap running to 2030. This is a moving target rather than a one off design exercise, so building regular reviews into packaging procurement decisions makes sense from this point forward.
pEPR sits alongside, rather than instead of, other packaging related obligations. The Plastic Packaging Tax has its own rate changes from April 2026. The UK Deposit Return Scheme for drinks containers remains on track for 1 October 2027, at which point containers that become deposit items will be excluded from EPR reporting to avoid producers paying twice for the same packaging.
A short checklist for food and drink businesses
Confirm your registration status with UK Packaging PRO if you have not already done so.
Check carefully whether your business meets the large or small producer thresholds for the current scheme year. Thresholds can shift as turnover and packaging volumes change year to year.
If you have not reviewed your packaging's likely Recyclability Assessment Methodology rating, start now. The move to recyclability based fees from the 2026 to 2027 year makes this a financial decision as much as a sustainability one.
Diary the 1 April and 1 October 2026 reporting deadlines. Late submission and late payment both carry real financial penalties.
If you operate any closed loop or take back collection, check whether the self managed waste offset is worth pursuing before the October 2026 mandatory reporting requirement applies.
Frequently asked questions
What is the penalty for paying a pEPR invoice late? The penalty is whichever is greater of 20 per cent of the unpaid fees, 5 per cent of UK turnover for a single registered organisation, or 2 per cent of UK group turnover for a business registered as a group. Notices of Liability are classed as statutory debt.
Is my business too small to be affected by pEPR? Not necessarily. Both the turnover threshold and the tonnage threshold must be met for a business to be obligated. A business with turnover above £1 million supplying more than 25 tonnes of packaging a year can still have reporting obligations as a small producer.
When do fees start reflecting recyclability rather than just weight? From the 2026 to 2027 scheme year. Before that, year one fees are flat base rates per tonne regardless of how recyclable the material is.
Do I need to register separately for the Deposit Return Scheme? Yes, and separately from pEPR. The Deposit Return Scheme launches on 1 October 2027. Containers that become deposit items will then be excluded from pEPR reporting to avoid double charging, but that is a 2027 change to plan for rather than act on now.
Who do I contact if I am unsure whether my registration is correct? UK Packaging PRO is the appointed Producer Responsibility Organisation and acts as the main point of contact for registration, data submission and fee queries.
REFERENCES
GOV.UK, extended producer responsibility for packaging, who is affected and what to do.
GOV.UK, extended Producer Responsibility for packaging, closed loop recycling.
GOV.UK, preparing for pEPR year one invoicing, key information for liable producers.
GOV.UK, year one extended Producer Responsibility for packaging fees update.
House of Commons Library, packaging extended producer responsibility, research briefing.
Beyondly, packaging EPR, a look ahead to 2026.
McGrady Clarke, 2026 guide to packaging EPR, extended Producer Responsibility.
Disclaimer: This article is for general information only and does not constitute legal, regulatory or financial advice. Food and Drink Network UK is not a regulatory or legal adviser. Fees, deadlines and obligations may change. Businesses should verify current requirements directly with PackUK, GOV.UK, or a qualified compliance specialist before making decisions based on this content.
