For years, Extended Producer Responsibility sat in the category of regulation that was always coming and never quite arrived. That's over. UK producers are now being invoiced under the reformed packaging EPR scheme, administered by PackUK, and the Year 2 framework introduces something that should change how every product business thinks about packaging: fees modulated by how recyclable your format actually is.
Most EPR coverage is written for compliance teams. This is written for Amazon brand owners who want to know three things: what it costs, what changes in Year 2, and what to do about it. At rankhouse we treat EPR as a P&L line like any other, because that's what it is now.
The scheme in ninety seconds
If your business places packaging on the UK market above the scheme thresholds, you pay fees designed to cover the full cost of collecting, sorting and processing that packaging when households throw it away. You report the weight of packaging by material, and you're charged per tonne. The money funds local authority waste services, and the design intent is blunt: make producers feel the disposal cost of their packaging choices, so they choose better packaging.
Year 1 base fees were confirmed as follows, per tonne: plastic £423, glass £192, paper and cardboard £196, aluminium £266, steel £259, wood £280, and fibre-based composites, the hardest category, £461.
| Year 1 (2025/26) | Year 2 (2026/27) | |
|---|---|---|
| Fee basis | Flat base fee per tonne of material | Modulated by recyclability (red, amber, green ratings) |
| Example rates | Plastic £423 per tonne; glass £192 per tonne | Illustrative fees published December 2025 show most materials rising |
| What good design earns | Nothing yet | Green-rated packaging pays less; red-rated pays a surcharge |
| Who pays | Producers and brand owners over the turnover and tonnage thresholds | Same, with 2025 data determining 2026 modulation |
| The seller takeaway | A cost line most P&Ls missed | Packaging choices now directly move the fee |
What Year 2 changes: the traffic light system
From the 2026-27 scheme year, flat base rates give way to modulated fees. Each material gets green, amber and red bands depending on the recyclability of the specific format, and the indicative Year 2 rates published by PackUK make the direction unmistakable:
- Plastic: £415 green, £455 amber, £545 red per tonne.
- Glass: £185 green, £205 amber, £245 red.
- Paper and card: £190 green, £210 amber, £250 red.
- Fibre-based composites: up to £630 per tonne in the red band, the most expensive number in the scheme.
Why Amazon brands feel this more than most
Three reasons. First, e-commerce products carry more packaging per unit sold than retail equivalents: the primary pack, often a secondary carton, and protective elements, all reportable. Second, FMCG categories like supplements, food and beauty lean on exactly the formats the scheme targets, from laminate pouches to composite tubs. Third, and most practically: Amazon brands live on thin, precisely-measured unit economics. A fee of a few pence per unit that arrives unmodelled is exactly the kind of cost that erodes a margin quietly for a year before anyone finds it.
Work an example. A 60-gram plastic container at the amber Year 2 rate of £455 per tonne carries about 2.7p per unit in EPR. A 10-gram pouch, even punished at the red rate of £545, carries about 0.5p. Multiply the gap by 200,000 units a year and the packaging decision is worth over £4,000 annually on this line alone, before the FBA and tax effects we've covered in the pouches versus bottles maths.
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Get the free audit at rankhouse.co.uk →The five jobs, in order
- Confirm your obligation. Thresholds are based on turnover and tonnage handled. Most established Amazon brands clear them. If you're near the line, check properly rather than hoping.
- Get real weights. Ask every packaging supplier for specification sheets with component weights by material. Reporting from spec sheets is dramatically easier and more accurate than weighing things in the warehouse, and accuracy matters, because over-reporting is donating money and under-reporting is a compliance problem.
- Map your formats to the traffic lights. The recyclability assessment methodology determines your band, and the difference between amber and red on plastic is £90 per tonne. If a laminate can become a mono-material film, or a composite tub can become mono-material, the switch now has a hard number attached.
- Put EPR into your per-unit economics. Not as a year-end lump. Per product, per unit, alongside referral fees, fulfilment and returns. That's the only way the packaging decisions above get made with real numbers. It's the same per-unit discipline we apply to everything else on the P&L.
- Remember it's not just the UK. If you sell into Germany, France or elsewhere in Europe, each market runs its own EPR regime with its own registration duties, and marketplaces are obligated to check compliance. Anyone planning European expansion should read our Germany playbook, where EPR registration sits on the critical path.
The strategic read
It's tempting to file EPR under regulatory nuisance. We'd argue it's something more useful: a scheduled, predictable cost increase on lazy packaging, announced years in advance, with published rates. Businesses that respond early get a double win, lower fees and a genuine sustainability story that increasingly matters to shoppers. Businesses that ignore it get a rising invoice and a scramble.
The fee schedules are public. The weights are on your spec sheets. The modelling takes an afternoon. This is one of those rare corners of Amazon economics where being on top of it is purely a decision, and it's exactly the kind of line we build into the per-product profit model every rankhouse client gets. If you don't know your EPR cost per unit today, that's fixable by Friday.
Questions we get asked about this
Who actually has to pay UK EPR fees?
Obligation is based on turnover and the tonnage of packaging you handle, with the full fee obligation landing on larger producers and lighter reporting duties below that. Most established Amazon brands importing or manufacturing their own packaged products clear the thresholds, and the definition of producer catches brand owners even where a co-packer physically fills the product. If you're near the line, take proper advice rather than assuming, because the scheme distinguishes between reporting obligations and fee obligations, and getting registration wrong in either direction is expensive: unnecessary fees one way, compliance exposure the other. The scheme administrator is PackUK, and registration routes run directly or through compliance schemes.
What's the practical difference between the green, amber and red rates?
Year 2 replaces flat per-material rates with modulation by recyclability: the same tonne of plastic costs £415 if the format is easily recyclable, £455 in the middle band, and £545 if it's hard to recycle, with equivalent spreads on every material and fibre-based composites reaching £630 in the red. The assessment is per packaging format, not per company, so a single product's primary pack, closure and carton can sit in different bands. The design message is deliberate: a 25 to 35% fee premium now separates lazy formats from good ones, which for the first time gives packaging engineers a hard annual number to justify recyclability work that used to be argued on values alone.
How do I get accurate weights without weighing everything in the warehouse?
Ask every packaging supplier for specification sheets, which state component weights by material as standard, and build your reporting from those. A product's reportable packaging is the sum of its parts: primary container, closure, label, any liner or seal, the retail carton, and your share of transit packaging. Spec-sheet reporting is faster and more accurate than scales, survives audits better, and makes scenario modelling trivial, because switching a component's material or weight in the spreadsheet immediately reprices your liability. The common errors run in both directions: forgetting small components under-reports, while double-counting transit packaging that a supplier already declares over-reports, and both are worth a careful first pass to eliminate.
How much does EPR actually add per unit sold?
Work one example and you'll have the method: a 60-gram plastic container at the amber Year 2 rate of £455 per tonne carries roughly 2.7 pence per unit; a 10-gram pouch even in the red band carries about half a penny. Paper cartons are cheaper still, and glass, while cheap per tonne at £192 to £245, is heavy, so per-unit figures can surprise. The point isn't that any single number is frightening. It's that at 100,000 to 500,000 units a year, the line runs from hundreds to tens of thousands of pounds, varies several-fold with packaging choices you control, and belongs inside per-unit economics next to referral and fulfilment fees rather than in a year-end compliance lump nobody attributes.
Does UK EPR cover me for selling into Europe?
No, and this trips up expanding brands constantly. Every European market runs its own EPR regime with separate registration, and Germany's is the strictest: registration and licensing are required before you place a single unit on the market, marketplaces are legally obliged to verify compliance, and non-compliance means delisting rather than a fine later. France runs parallel schemes with their own identifiers. If European expansion is in your plan, EPR registrations sit on the critical path alongside VAT, weeks-to-months of lead time, done before launch rather than after. It's one of the workstreams we route through specialists, and it's covered properly in our Germany launch playbook.
UK packaging EPR is now a real invoice administered by PackUK, charged per tonne of packaging by material, with Year 1 base fees from £192 for glass to £461 for fibre composites and plastic at £423. Year 2 introduces the traffic-light system: the same tonne of plastic costs £415 recyclable, £455 mid-band or £545 hard-to-recycle, a deliberate 25 to 35% premium on lazy formats. Amazon brands feel it more than most because e-commerce carries more packaging per unit and lives on precise unit economics, where an unmodelled few pence per unit erodes margin quietly for a year. The five jobs: confirm your obligation, get component weights from supplier spec sheets, map every format to its band, put EPR into per-unit economics alongside referral and fulfilment fees, and remember every European market runs its own separate regime. The scheme is a scheduled, predictable cost increase on poor packaging, announced in advance, with published rates. Responding early is purely a decision.
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- Packaging extended producer responsibility — House of Commons Library. https://commonslibrary.parliament.uk/research-briefings/cbp-10352/
- PackUK touts increased EPR rates for 2026 — edie. https://www.edie.net/packuk-touts-increased-epr-rates-for-2026/
- Y2 illustrative EPR base fees for 2026 announced by PackUK — Clarity. https://clarity.eco/news/y2-illustrative-epr-base-fees-for-2026-announced-by-packuk/
About the author
Daniel Whalley is the founder of rankhouse, a boutique specialist agency for Amazon-focused growth in FMCG, health, wellness and beauty brands. He has spent 10 years inside Amazon accounts, generating £100M+ for the brands he works with, and manages £500k+ a month in ad spend across the UK, Europe and the US. He writes from inside the accounts he runs, not from the sidelines. Connect on LinkedIn → · amazon@rankhouse.co.uk