In brief: From the 2026-2027 scheme year, the UK’s Extended Producer Responsibility (EPR) scheme for packaging moved from flat-rate fees to fees that are eco-modulated by recyclability. Packaging rated Red under the government’s Recyclability Assessment Methodology now costs 1.2 times the base rate, rising to 1.6 times in 2027-2028 and 2.0 times in 2028-2029, while Green-rated packaging currently attracts roughly a 9% discount. The scheme covers online marketplace operators enabling sales into the UK as well as direct retailers, which makes packaging choice a direct and escalating cost line rather than a soft sustainability commitment.
Sustainable ecommerce practices in the UK moved from a reputational consideration to a quantified cost line in 2026, when the government’s packaging fee system began actually charging different rates based on how recyclable a retailer’s packaging is. This isn’t a future proposal; it’s the fee structure that applies from the current scheme year, with the financial gap between recyclable and hard-to-recycle packaging set to widen automatically over the next three years regardless of any further policy change.
UK Packaging Fees Now Reward Recyclable Materials Directly
The Extended Producer Responsibility (EPR) scheme for packaging, established under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, has required obligated businesses to report their packaging data since 2024, with the first fee invoices issued from October 2025 based on 2024 tonnages. From the 2026-2027 scheme year onward, those fees stopped being a single flat rate per material and started being eco-modulated according to the government’s Recyclability Assessment Methodology (RAM), which rates all in-scope packaging as Red, Amber, or Green, part of the same wider push toward regulatory tightening UK retailers have faced through 2026.
The scheme administrator, PackUK, has set the modulation on an escalating scale. Packaging rated Red, meaning not currently recyclable at scale, costs 1.2 times the Amber base rate for 2026-2027, rising to 1.6 times in 2027-2028 and 2.0 times in 2028-2029. Green-rated packaging, the most recyclable category, currently attracts an estimated 9% discount against the Amber rate, though PackUK has said this Green discount figure is illustrative and calculated from current RAM data rather than fixed permanently. Crucially, modulation doesn’t increase the total fees collected across the scheme; it reallocates the existing cost burden toward harder-to-recycle materials and away from more recyclable ones.
Who the New Fees Actually Apply To
The scheme applies to organisations with an annual turnover of £1 million or more that handle over 25 tonnes of packaging a year, covering primary, secondary, tertiary, and shipment packaging, including reusable and hireable packaging. Brand owners, importers of packaged goods, and businesses that pack or fill products under their own brand are all in scope as obligated producers.
The detail that matters most for this site’s audience is that online marketplace operators enabling international sales into the UK are explicitly included in scope alongside direct retailers, which means a business selling through a marketplace doesn’t automatically sit outside the fee system just because a third-party platform handles the sale. Retailers using multiple fulfilment routes, their own site, a marketplace, or a mix of both, need to establish which entity in that chain is the obligated producer for each packaging type they use, rather than assuming responsibility sits entirely with whichever platform processes the transaction.
What This Means for Ecommerce Packaging Decisions
The practical implication of eco-modulation is that a packaging choice a retailer might previously have made purely on cost or protective performance now carries an additional, quantified, and growing financial consequence tied specifically to recyclability. A retailer using Red-rated packaging in 2026-2027 is already paying 20% more than the base rate for that material, and that multiplier is scheduled to reach double the base rate by 2028-2029 without any further legislative change required to make it happen.
Getting a RAM rating checked for current packaging, rather than assuming a material is “recyclable” in a general sense, is worth doing directly, since the RAM assessment is specific about what counts as recyclable at scale under the scheme’s methodology rather than what’s theoretically recyclable somewhere in principle. Retailers reviewing packaging redesigns should weigh the modulated fee saving against material cost and protective performance together, since a cheaper but Red-rated material may cost more overall once the escalating fee multiplier is factored in over a multi-year horizon, particularly by the time the 2.0x rate applies in 2028-2029.
Reporting and Compliance Steps Retailers Need Now
Obligated producers need to register with PackUK, either directly or through a recognised compliance scheme, and submit packaging data covering the materials, weights, and recyclability of everything they place on the market. Reporting periods align with the calendar year, and the environmental regulators, the Environment Agency and its devolved equivalents, audit reported data rather than simply accepting self-reported figures at face value, which makes accurate record-keeping a genuine compliance requirement rather than a formality.
The invoicing timeline is worth understanding clearly, since it lags the reporting period it’s based on. Fees for a given scheme year are calculated from packaging data reported for the previous year’s tonnages, and the first invoices reflecting the new modulated rates are expected in the second half of 2026, covering packaging placed on the market in 2025. A retailer that hasn’t yet reviewed its current packaging against RAM ratings has a narrowing window to make design changes before those changes show up in a future year’s modulated fee bill, since redesigning packaging now affects 2026 tonnage data, which in turn affects fees invoiced later.
Small producers, defined by turnover and packaging volume thresholds below the main scheme’s £1 million and 25 tonne cut-offs, face reduced obligations but still need to report packaging data to remain compliant, so smaller ecommerce retailers shouldn’t assume they sit entirely outside the scheme without checking their specific figures against the current thresholds.
Returns Remain the Other Major Sustainability Cost
Packaging fees aren’t the only sustainability-linked cost UK ecommerce retailers are dealing with. Returns handling carries its own environmental footprint, through reverse logistics transport, the packaging used for returns specifically, and the disposal or write-off of stock that can’t be resold at full price, and that footprint sits alongside the direct financial cost of returns discussed in this site’s fulfilment and logistics coverage. Packaging decisions and returns handling aren’t entirely separate problems either: packaging that protects an item well enough to prevent damage-driven returns reduces both the environmental cost of a wasted item and the reverse-logistics cost of processing an avoidable return.
Retailers reviewing packaging for EPR fee reasons have a natural opportunity to review it for returns-reduction reasons at the same time, since better-fitting or better-protective packaging can lower both the modulated fee exposure, if it moves a material toward a Green rating, and the rate of damage-related returns, without treating the two reviews as competing priorities. Both reviews ultimately serve the same underlying goal, reducing the amount of packaging material a retailer needs to place on the market at all, which is the one lever that reduces exposure to modulated fees regardless of which rating any given material eventually achieves.
Return packaging specifically deserves its own attention rather than being treated as identical to outbound packaging. An item returned in its original packaging generates a second EPR-relevant tonnage event where a retailer supplies additional void fill, tape, or a replacement box to complete the return, and a retailer that has moved outbound packaging to a Green-rated material but continues supplying Red-rated materials for returns handling is only capturing part of the available fee saving.
Reviewing returns packaging against the same RAM criteria used for outbound packaging closes that gap, and it’s a smaller, more contained change than a full outbound packaging redesign, which makes it a reasonable starting point for retailers wanting a quick win before tackling the larger packaging review.
FAQs
When did the UK’s packaging fees actually become eco-modulated? From the 2026-2027 scheme year. The first invoices reflecting the new modulated rates are expected in the second half of 2026, covering packaging placed on the market in 2025.
How much more does Red-rated packaging cost under the new system? 1.2 times the Amber base rate for 2026-2027, rising to 1.6 times in 2027-2028 and 2.0 times in 2028-2029. Green-rated packaging currently attracts roughly a 9% discount against the Amber rate.
Do online marketplace operators have to pay these packaging fees too? Yes. Online marketplace operators enabling international sales into the UK are explicitly included in scope alongside direct retailers, so selling through a marketplace doesn’t automatically remove a business’s packaging fee obligations.
Is my current packaging automatically “recyclable” under this scheme? Not necessarily. The Recyclability Assessment Methodology (RAM) rates packaging based on whether it’s recyclable at scale under the scheme’s specific methodology, which can differ from a general assumption that a material is recyclable. Getting an actual RAM rating checked is the only reliable way to know which fee tier applies.
Do small ecommerce retailers need to register with PackUK? Smaller producers below the main £1 million turnover and 25 tonne packaging thresholds face reduced obligations, but still need to report packaging data to remain compliant. It’s worth checking specific figures against the current thresholds rather than assuming exemption.
