For many organisations, Extended Producer Responsibility (EPR) is still being treated as a compliance task – something to submit and move on from. However, the businesses looking more closely at their packaging data are starting to realise something different: EPR is one of the clearest opportunities to reduce costs associated with packaging.
The reason for this is that EPR doesn’t just charge you for the volume of packaging you place on the market, it charges you based on how that packaging is designed, how recyclable it is and how accurately it’s reported. That means two organisations with similar products can end up paying very different fees, depending on how well they understand and manage their data.
This is where many businesses are missing value. Packaging data is often incomplete, inconsistent, or pulled together at the last minute. Materials get grouped into broad categories, assumptions are made to fill gaps, and in some cases, packaging is effectively treated as “worst case” just to ensure compliance. The result is that organisations can default into higher fee categories without realising it, paying more than they need to year after year.
An EPR assessment changes that. It looks beyond submission and focuses on what’s genuinely increasing cost. Through analysing packaging formats, increasing data accuracy and identifying where materials fit within recyclability criteria, inefficiencies can be identified and exposure to higher fees reduced. It is about turning ambiguous data into unambiguous decisions and in many cases, high-cost packaging into lower-cost alternatives.
As EPR reporting requirements continue to evolve, the organisations that treat EPR as a cost lever rather than a compliance exercise will be in a much stronger position. Not just to stay compliant, but to actively reduce costs and make more informed packaging decisions over time.
One of the most significant developments within EPR is the introduction of modulated fees, which are designed to reflect the recyclability of packaging materials. From April 2026, these fees will be adjusted using the Recyclability Assessment Methodology (RAM), a framework that assigns each packaging format a recyclability rating. This marks a clear shift in direction, moving away from flat or generalised cost structures toward a more targeted approach that incentivises better packaging design.
Under RAM, packaging is assessed and categorised using a Red, Amber, or Green (RAG) rating system. Red-rated packaging is considered difficult to recycle, often due to material composition, lack of infrastructure, or contamination risks. Amber-rated packaging represents transitional materials, which may be recyclable under certain conditions but are not yet widely supported. Green-rated packaging, on the other hand, is widely recyclable and aligns with existing collection and processing systems.
This classification system has direct financial consequences. Packaging that falls into the Red category will incur increasing surcharges over time, with a 20% increase applied in 2026–27, rising to 60% in 2027–28, and reaching 100% by 2028–29. In contrast, Green-rated packaging will benefit from reduced fees, with the exact level of discount determined by the scheme administrator. This structure is designed to encourage organisations to move away from difficult-to-recycle materials and toward more sustainable alternatives.
While the intention of this system is to support the transition to a circular economy, it also introduces a level of financial exposure that many organisations have not previously had to manage. Packaging decisions that were once driven by cost, functionality, or branding must now also account for recyclability and compliance costs. As a result, businesses that do not fully understand how their packaging is assessed may find themselves facing higher fees than expected.
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