By Ellis Clark
Extended Producer Responsibility (EPR) is turning packaging data into a financial risk, making early assessment essential for cost control and future competitiveness.
Extended Producer Responsibility (EPR) is changing how businesses account for the packaging they place on the market. For producers, importers and brand owners, it is no longer enough to submit packaging data as an annual compliance task. Under the UK’s evolving EPR framework, packaging design, recyclability and data quality are becoming directly linked to cost. For Dr William Beer, CEO of Tunley Environmental, the key message is that businesses who understand their packaging data early will be better placed to reduce future fees and avoid avoidable compliance risk.
Why is EPR now a board-level cost issue?
EPR has historically been viewed as a regulatory requirement to manage in the background. Packaging data was gathered, forms were submitted, and the process was often treated as an administrative obligation rather than a strategic cost issue.
That approach is becoming increasingly risky because the UK’s EPR for packaging scheme is designed to move more of the cost of managing packaging waste onto the businesses that place packaging on the market. Official UK Government guidance explains that organisations may need to report packaging data and pay fees depending on turnover, packaging tonnage and the packaging activities they carry out: GOV.UK EPR guidance.
A business’s financial impact is not solely determined by the quantity of packaging it utilises. The classification, recycling, and reporting quality of the packaging all contribute to its impact. This suggests that the cost results achieved by two businesses with comparable product lines may vary based on the quality of their data and the design of their packaging.
What makes EPR different from previous packaging compliance?
EPR creates a stronger link between packaging decisions and producer costs. Packaging that is difficult to recycle is likely to become more expensive over time, while packaging that aligns better with recycling systems should be better positioned under future fee structures.
For 2025, PackUK published base fees for different packaging materials, including £423 per tonne for plastic, £196 per tonne for paper and card, £192 per tonne for glass, £266 per tonne for aluminium and £461 per tonne for fibre-based composite materials: PackUK 2025 base fees.
The next major development is fee modulation. PackUK has confirmed that disposal fees will be adjusted based on recyclability, using a red, amber and green rating system under the Recyclability Assessment Methodology (RAM): PackUK modulation statement.
In practical terms, this means packaging will increasingly be assessed not only by weight or material type, but by how well it performs within recycling systems.
| Packaging rating | What it generally means | Business implication |
| Green | Widely recyclable and aligned with collection and processing systems | Lower cost exposure and stronger compliance position |
| Amber | Recyclable only under certain conditions or with limitations | Transitional risk requiring review and monitoring |
| Red | Difficult to recycle due to material, format or infrastructure barriers | Higher cost exposure and greater redesign pressure |
Why do businesses risk overpaying?
One of the biggest risks under EPR is poor data. Packaging information is often held across different teams, suppliers and systems. Procurement may hold supplier specifications, operations may understand packaging use, finance may hold sales and turnover data, while sustainability or compliance teams may be responsible for reporting.
When this information is incomplete or inconsistent, businesses can end up relying on assumptions. That creates several cost risks:
- packaging volumes may be over-reported due to duplication or conservative estimates;
- materials may be incorrectly classified;
- packaging may be treated as less recyclable than it is because evidence is missing;
- imported goods may lack sufficient packaging composition data;
- teams may be unable to identify which formats are driving the highest fees.
In the early stages of reporting, some businesses may choose cautious assumptions to ensure they comply. However, caution can become expensive if it places packaging into higher-cost categories unnecessarily. As EPR fees become more closely linked to recyclability, weak data may translate directly into higher costs.
How can an EPR assessment reduce costs?
An EPR assessment provides a structured way to understand obligations, validate data and identify packaging formats that may increase future fee exposure. It turns packaging reporting from a reactive exercise into a cost management process.
A practical assessment should usually include three stages.
1. Establish the obligation
The first step is to understand whether the organisation is in scope and what reporting duties apply. This includes reviewing turnover, packaging tonnage, business structure and relevant packaging activities. Under UK guidance, large producers and small producers have different thresholds and reporting requirements, so understanding the correct classification is essential.
2. Validate packaging data
The next step is to review packaging materials, weights, formats, classifications and evidence sources. This helps identify gaps, duplication and assumptions that may lead to inaccurate reporting or unnecessary cost.
3. Assess recyclability and redesign opportunities
Once the data is clearer, packaging can be reviewed against recyclability criteria. This allows businesses to see which formats may attract higher fees and where changes could improve recyclability. In many cases, improvement does not require a complete packaging redesign. Smaller changes, such as simplifying material combinations, reviewing labels or improving supplier evidence, may help reduce exposure.
Why should EPR involve more than the compliance team?
EPR is not only a reporting issue. It affects procurement, product design, supply chain management, finance, sustainability and customer communication. If it remains isolated within a compliance function, the business may miss opportunities to reduce cost and improve packaging performance.
A stronger approach brings teams together around a shared packaging data process. Procurement can engage suppliers for better specifications. Product teams can review material choices and formats. Finance can model potential fee exposure. Sustainability teams can assess environmental impact. Commercial teams can understand how packaging improvements may support customer expectations and market positioning.
This joined up approach also helps avoid unintended consequences. For example, reducing packaging weight may lower material use, but it could increase product damage if not assessed carefully. Switching to a more recyclable material may reduce EPR exposure, but it may affect shelf life, transport efficiency or product protection. Good EPR decisions therefore need both environmental and commercial evidence.
What should businesses do next?
The organisations that act early will have more time to improve data quality, engage suppliers and phase in packaging changes before higher costs become embedded.
A practical starting point is to:
- confirm whether the organisation is in scope;
- identify whether it is classified as a small or large producer;
- build a central packaging data inventory;
- validate packaging weights, materials and classifications;
- review packaging against recyclability criteria;
- identify high-risk or high-cost formats;
- assign ownership across procurement, sustainability, finance and product teams.
This does not mean every business must immediately redesign its packaging. It does mean businesses need to understand where the risks are. Once that baseline is clear, decisions can be prioritised according to cost, feasibility and environmental impact.
Conclusion
EPR is changing the economics of packaging. What was once a compliance submission is becoming a live cost issue linked to data quality, recyclability and packaging design. Businesses that treat EPR as an annual reporting task may find themselves paying more than necessary, particularly as modulated fees develop.
The forward-looking approach is to assess packaging early, validate the data and identify where design choices create future cost exposure. In a more circular economy, better packaging decisions will not only support compliance. They will also help businesses control costs, reduce waste and make more informed decisions about the products they place on the market.
Ellis Clark
