EPR Guide - Flipbook - Page 22
Upcoming Changes and Phase In: Modulated
Fees & Recyclability Incentives
The most signi昀椀cant change on the horizon (from 2026 onwards) is the move to “modulated” EPR
fees. This means the amount a company pays will depend not just on weight and material, but on how
recyclable that packaging is in real-world UK waste systems. This section explains how fee modulation
works, along with other upcoming EPR features like the Recyclability Assessment Methodology (RAM),
labelling, and future adjustments.
Modulated Fees and RAM (Recyclability Assessment Methodology)
Starting with fees due in late 2026 (for 2025 data), the UK introduced RAM-based fee modulation.
Under RAM, every packaging component gets a recyclability rating: Green (highly recyclable), Amber
(moderately recyclable), or Red (not recyclable at scale). PackUK applies multipliers so that:
• Green-Rated Packaging – widely recyclable materials – pays lower fees (discounted below the
base rate)
• Amber-Rated Packaging – “average” recyclability – pays the base fee (the baseline cost per
tonne)
• Red-Rated Packaging – hard-to-recycle or non-recyclable – pays signi昀椀cantly higher fees (a
surcharge above the base rate).
The modulation schedule is stepped up in the coming years:
• 2026-27: Red packaging incurs roughly 1.2x the base fee, and Green packaging somewhat
less than base fee.
• 2027-28: Red multiplier rises to 1.6x base fee (Green correspondingly gets a bigger discount).
• 2028-29: Red-rated packaging will cost 2.0x the base fee (200%), effectively double the rate
of fully recyclable packaging.
This “traf昀椀c light” fee system creates a powerful incentive to switch away from Red materials. For
instance, in 2026 a Red packaging might pay ~20% more per tonne than Amber, but by 2028 it
will pay 100% more. Conversely, invest in redesign to get a Green rating and you could cut your fees
signi昀椀cantly. The difference between a Green vs Red rating in 2026 is estimated at over 30% in cost
(about £130 per tonne difference for certain materials), and this gap will widen with time.
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