UK Packaging EPR 2026/2027: Fees, RAM and Recyclability Ratings Explained

UK packaging EPR’s 2026/27 assessment year needs to be read separately from the packaging supply year. In the official sources checked 18 October 2026, the published per-tonne table is still labelled illustrative. PackUK’s August operational plan schedules Year2 fee calculation for November 2026 and initial notices by the end of that month. The December 2025 illustrative rates below are planning inputs, not confirmed invoice rates. [R3] [R4]

The other important change is modulation. From the 2026/27 assessment year, household packaging waste disposal fees are adjusted according to Recyclability Assessment Methodology (RAM) ratings. Amber packaging pays the base disposal fee, red packaging pays a premium, and green packaging receives a discount funded from the red premium pool. [R5]

For producers, the difficult part is not just the fee table. Three different clocks interact: the year packaging is supplied, the reporting/RAM year, and the later assessment year in which PackUK issues the notice of liability. Understanding that sequence is essential for budgeting and packaging redesign.

What does “UK Packaging EPR 2026/27” actually mean?

The 2026/27 assessment year runs from 1 April 2026 to 31 March 2027. PackUK’s notice-of-liability guidance says the notice for an assessment year is based on packaging supplied in the previous calendar year. A producer must pay a notice of liability when it is a producer in the current assessment year and supplied household packaging as a large producer in the previous calendar year. [R2]

That means the Year 2 fee cycle links two periods:

• calendar year 2025: the packaging that creates the relevant Year 2 household-packaging tonnage and RAM profile;
• assessment year 2026/27: the period in which PackUK calculates and charges the corresponding producer liability.

This distinction prevents a common mistake: assuming that a packaging redesign made in late 2026 can retroactively reduce the 2026/27 fee. In general, Year 2 liability reflects the packaging supplied in 2025, subject to the scheme’s detailed rules and any accepted corrections or appeals.

Who is affected by the disposal-fee regime?

UK EPR obligations depend on establishment, packaging activity, tonnage and turnover. Current GOV.UK guidance says an organisation is within the EPR threshold framework if it is established in the UK, supplied or imported more than 25 tonnes of packaging in the previous year, and has worldwide annual turnover of at least £1 million. Large and small producers then have different obligations. [R1]

For the current large-producer threshold, the guidance classifies an obligated producer as large when annual turnover is more than £2 million and packaging supplied or imported is more than 50 tonnes. Producers in the lower obligated band are small producers and do not carry the same disposal-fee and RAM obligations. [R1]

See the general packaging EPR guide for producer roles across jurisdictions.

The disposal-fee question is narrower again. PackUK says a producer must pay a notice of liability when it is a producer during the current assessment year and supplied household packaging as a large producer in the previous calendar year. A compliance scheme may assist with reporting and compliance functions, but PackUK’s current guidance says it cannot pay the notice of liability on the producer’s behalf. [R2]

Three clocks explain most of the confusion

Editorial synthesis of the identified source provisions and evidence boundaries; illustrative examples are not product test results or compliance determinations.

The second and third rows are an editorial mapping of PackUK’s “previous calendar year” notice rule, the RAM version guidance and the published modulation-factor schedule. They are useful for planning, but the exact assessment-year treatment should be rechecked against PackUK’s then-current instructions before a producer files or budgets a statutory liability. [R2] [R5] [R6]

Confirmed 2026/27 fees were still pending at the source cutoff

This is the most important current-status point.

PackUK published a Year 2 illustrative fee table in December 2025. That older page originally said confirmed 2026/27 fees were expected in June 2026. However, the later operational plan, updated in August 2026, supersedes that planning expectation for current status: PackUK says it remained unable to calculate confirmed Year 2 disposal fees until producer data had been received and checked, and that the data would be used to calculate the fees in November 2026. The same operational plan says PackUK intends to issue the initial Year 2 notice of liability by the end of November 2026. [R3] [R4]

Producers should therefore distinguish:

• illustrative per-tonne fees: public planning estimates from December 2025;
• confirmed Year 2 per-tonne fees: not yet published at the 18 October 2026 cutoff;
• the notice of liability: the producer-specific statutory liability that PackUK intends to issue by the end of November 2026.

That distinction is not semantic. An internal budget that labels the illustrative table as a final tariff can overstate the certainty of the liability.

What the December 2025 illustrative fees show

The current public illustrative table gives green, amber and red estimates for eight material categories. PackUK explicitly says the figures are intended for early visibility, are likely to change, and do not include regulator registration charges or the separate cost of meeting packaging recycling targets such as PRN/PERN obligations. [R4]

Illustrative December 2025 rates only; £ per tonne, rounded to nearest £5. These are not confirmed liability rates.

In this table, amber is the base fee. The Year 2 red rate is 1.2 times the amber rate. The green rates used an illustrative discount of about 9%, but PackUK states that the actual green discount depends on the final mix of red and green tonnage reported into the system. [R4]

That means the red premium is structurally easier to forecast than the green discount. The red multiplier is set by the modulation policy; the green discount is a redistribution result that cannot be finalised until the relevant tonnage data is known.

How fee modulation works

PackUK’s modulation policy is designed to reallocate the disposal-fee burden rather than increase the overall household-packaging disposal-fee envelope simply because modulation exists. Amber packaging remains at the base disposal fee. Red-rated packaging pays a multiplier above that base. The additional revenue collected from red-rated tonnage creates a pot that reduces the fees charged to green-rated packaging. [R5]

Editorial synthesis of the identified source provisions and evidence boundaries; illustrative examples are not product test results or compliance determinations.

The green discount is different. PackUK calculates the value generated by red premiums across materials and redistributes that value across green tonnage. The resulting percentage discount is therefore data-dependent. PackUK’s policy states that final modulated fees can only be published once the relevant reporting-year data is available. [R5]

This is why a business should not build a long-term business case around the December 2025 “green = approximately 9% discount” figure. It was an illustrative Year 2 estimate, not a permanent policy percentage.

What RAM red, amber and green actually mean

RAM is the scheme’s recyclability assessment methodology. Its purpose is to assess how packaging performs through the UK recycling system and to generate the rating used in fee modulation.

The current RAM 2027 overview separates classification from four essential recyclability stages:

1. collection;
2. sortation;
3. reprocessing; and
4. application of the resulting recyclate. [R6]

PackUK says “recycled at scale” requires evidence that packaging is actually moving through those stages in existing, proven infrastructure rather than only a pilot or experimental route, and that the system has enough capacity for the packaging volume supplied. [R6]

Illustrative December 2025 rates only; £ per tonne, rounded to nearest £5. These are not confirmed liability rates.

RAM ratings are not the same thing as a consumer-facing recycling label. PackUK expressly says the RAM rating is not related to other recyclability labelling that may appear on a package. [R6]

Collection thresholds matter, but they are only one stage

RAM 2027 provides a concrete example of how a rating depends on real infrastructure rather than material theory. At the collection stage, a package or component must be collected at kerbside by at least 75% of UK local authorities to receive a green collection-stage rating. If collection reaches at least 50% but remains below 75%, the item can continue through later stages with its collection outcome capped at amber. Packaging outside those collection categories is normally red at that stage unless it meets the specific take-back evidence route. [R6]

That does not mean “75% collection = final green.” Sortation, reprocessing and application still have to be assessed. A package can pass the collection stage and still receive a worse final result because the recycling system cannot sort it reliably, reprocess it efficiently or find an established end use for the recyclate.

Which RAM version applies in 2026 and 2027?

This is another area where the dates are easy to misread.

PackUK’s current RAM 2027 overview says:

• large producers should use RAM version 1.1 for the 2026 reporting year, from 1 January to 31 December 2026;
• large producers should use RAM 2027 for the 2027 reporting year. [R6]

RAM 2027 also changes how the methodology is presented. Classification is performed first, and the item or component is then evaluated through the four essential stages of collection, sortation, reprocessing and application. Earlier RAM material described classification as the first of five stages. [R6]

For a packaging-development team, the consequence is that one static RAM assessment should not be treated as permanent. PackUK says the methodology will be updated annually. A construction that was assessed under version 1.1 should therefore be re-mapped when a later reporting year requires a newer version.

See our narrower RAM version and reporting guide.

Rigid and flexible plastic: reporting subcategory does not equal a separate Year 2 tariff

PackUK has specified two subcategories within the plastic category: plastic — rigid and plastic — flexible. For Year 2, those subcategories apply to large producers and compliance schemes for packaging supplied in 2025 and are relevant to record-keeping and data-reporting obligations. [R7]

But the current December 2025 Year 2 illustrative fee table still publishes one material row for Plastic, with one green/amber/red set of illustrative rates. [R4]

So the safe interpretation is:

Rigid/flexible is a Year 2 reporting subcategory, but the latest published Year 2 illustrative fee table does not yet show separate rigid-plastic and flexible-plastic per-tonne tariffs.

PackUK’s subcategory policy says those rigid/flexible distinctions are intended to become relevant to producer disposal-fee obligations in Year 3. [R7]

What should producers do before the Year 2 notice arrives?

By the 18 October 2026 source cutoff, the key Year 2 correction deadline has already passed. PackUK set 1 September 2026 as the deadline for 2025 packaging-data resubmissions to affect the planned Year 2 notices. Its operational plan says it will not recalculate a notice of liability for producers that resubmitted packaging data after that date, although successful appeals can still lead to an individual recalculation. [R3]

The immediate work is therefore narrower than “keep changing the 2025 data until the fee looks right.” Producers should instead:

1. reconcile the 2025 tonnage and RAM data that PackUK will use, so finance and compliance teams understand the basis of the forthcoming notice;
2. budget with scenarios rather than a single assumed rate, because the December table is illustrative and the green discount is data-dependent;
3. check the RPD primary contact and payment workflow, because PackUK delivers the notice through the RPD portal and the holding company pays where a group is registered;
4. separate Year 2 liability from future design work: redesigns to improve 2026 or 2027 RAM outcomes influence later cycles, not the 2025 packaging already underlying Year 2;
5. keep auditable RAM evidence by item/component, especially where a rating depends on collection, sortation, specialist reprocessing, take-back or end-use evidence.

Once the notice is issued, PackUK says payment is usually made in quarterly instalments according to the dates stated on the notice. The notice also sets out the disposal fee, administration/public-information/impairment charges, modulation, complaint route and appeal rights. [R2]

How large is the Year 2 system forecast?

PackUK’s 2026/27 operational plan forecasts £1.47 billion of chargeable local-authority disposal costs across the UK. It also forecasts £28 million in administration costs and £60 million in impairment, producing approximately £1.558 billion of total forecast fees to be recovered. [R3]

These are system-level forecasts, not a producer’s per-tonne tariff. The per-tonne outcome depends on material categories, obligated tonnage and modulation. A producer should therefore not divide the national total by its own reported tonnes to estimate liability.

What remains unresolved on 18 October 2026?

For Year 2, the most consequential missing public number is the confirmed per-tonne disposal-fee table. PackUK’s current operational plan points to calculation in November and an initial notice of liability by the end of November 2026. [R3]

For later years, two moving parts deserve continued attention:

• RAM methodology: PackUK says it will update RAM annually, so material-specific criteria and evidence routes can change between reporting years;
• modulation: the red multiplier is currently published through 2028/29, but the green discount remains a function of reported market tonnage rather than a fixed percentage. [R5] [R6]

The practical reading of UK packaging EPR in late 2026 is therefore not “the fee is £X per tonne.” It is a sequence: identify whether the producer is liable, map the correct packaging-supply year to the assessment year, apply the RAM version required for that reporting year, distinguish illustrative from confirmed rates, and then reconcile the actual notice of liability when PackUK issues it.

Official sources and reference notes

1. [R1] Defra / Environment Agency. Check if you must comply with EPR for packaging. Live source. UK establishment/threshold guidance; >25 tonnes + £1m obligated threshold; current large-producer table (>£2m and >50 tonnes); 2026 reporting-year context. Relevant public text checked 18 October 2026; source scope retained. Accessed 18 October 2026.
2. [R2] PackUK / Defra. Extended producer responsibility for packaging: notice of liability. Live source. Notice based on previous calendar year; assessment year 1 Apr–31 Mar; liable producer scope; holding-company payment; compliance scheme cannot pay; notice contents; usual quarterly payment; complaints/appeal route. Relevant public text checked 18 October 2026; source scope retained. Accessed 18 October 2026.
3. [R3] PackUK. PackUK operational plan: 2026 to 2027. 10 August 2026. PackUK still unable to calculate confirmed Year 2 fees until data checks; calculation in November; initial notice target end-November; single Year 2 notice policy; 1 Sep resubmission treatment; £1.47bn disposal / £28m admin / £60m impairment / £1.558bn forecast. Relevant public text checked 18 October 2026; source scope retained. Accessed 18 October 2026.
4. [R4] PackUK / Defra. Illustrative waste disposal fees 2026: Extended producer responsibility for packaging. 19 December 2025. Illustrative green/amber/red table; amber base; Year 2 red +20%; illustrative green ~-9%; methodology and uncertainty; exclusions for regulator registration/PRN-PERN costs. Relevant public text checked 18 October 2026; source scope retained. Accessed 18 October 2026.
5. [R5] PackUK. Producer disposal fees modulation statement. 17 February 2026. Red modulation factors 1.2 / 1.6 / 2.0 for 2026/27–2028/29; amber at base; green discount funded from red premium and data-dependent. Relevant public text checked 18 October 2026; source scope retained. Accessed 18 October 2026.
6. [R6] PackUK. RAM 2027: overview. 20 August 2026. RAM v1.1 for 2026 reporting; RAM 2027 for 2027; classification + collection/sortation/reprocessing/application; 75%/50% collection thresholds; take-back route; definitions of red/amber/green; RAM ratings not consumer labels; annual updates. Relevant public text checked 18 October 2026; source scope retained. Accessed 18 October 2026.
7. [R7] PackUK. PackUK: specifying material subcategories under regulation 7(11). 19 December 2025. Plastic-rigid and plastic-flexible subcategories; Year 2 record/reporting role; Year 3 intended relevance to disposal-fee obligations. Relevant public text checked 18 October 2026; source scope retained. Accessed 18 October 2026.