Defra releases initial pEPR base fees

It relates to fees that would be charged to obligated packaging producers by the Scheme Administrator (SA). It does not cover:

• Regulator charges, imposed by the Environment Agency, the Scottish Environment Protection Agency, the Northern Ireland Environment Agency and Natural Resources Wales
• Costs associated with meeting packaging recycling targets e.g. through the purchase of Packaging Waste Recycling Notes (PRNs)

The document acts on behalf of the UK government, the Department for Agriculture, Environment and Rural Affairs (DAERA) in Northern Ireland, the Scottish Government and the Welsh Government.

Fees will be incurred from 1 April each year, based on packaging supplied by registered producers for the preceding calendar year. The deadline for reporting data on RPD is 1 April. As a result, fee rates for the first year of EPR for packaging (2025/26) won’t be known until after 1 April 2025.

Each obligated producer’s fees will be calculated by the SA using the fee formula built into the Fees and Payments Calculator (FPC). The legal provisions for the fee formula are set out in the draft Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations.

Defra has said that the illustrative base fees for eight packaging categories act as a response to industry calls for “greater clarity” about the costs they are likely incur.

The fees have been calculated using different datasets to those the SA will use to calculate actual fees, but are being shared “as early as possible to best support producers”.

Table 1: Illustrative EPR for packaging base fees rates for 2025/26 for all packaging except glass

Table 2: Illustrative EPR for packaging base fees rates for 2025/26 for glass packaging

The illustrative base fees have been calculated using weights of household packaging placed on the market in 2022, taken from the ‘PackFlow Refresh 2023’ reports.

Defra said that the data submitted by producers in the Report Packaging Data (RPD) online portal have not been used due to identification of “anomalies” which require rectification.

The fees in Table 1 include estimations of Local Authority (LA) packaging waste management costs by the Waste & Resources Action Programme (WRAP).

Illustrative base fees are being provided separately for glass (Table 2) as these were said to be estimated using a separate methodology to ascertain LA costs being developed by Defra, which will be used to calculate final EPR for packaging base fees.

Defra added that while these illustrative base fees can help industry with “early preparedness”, the figures are still subject to “significant uncertainty” and will change in the future. The government intends to publish refined figures for the illustrative base fees in September 2024, once the data received via the Government’s RPD online portal has been further reviewed and evaluated. Illustrative fees are also subject to the 2024 spending review.

‘Modulated’ 2026 fees 

From year 2 of EPR, fees will be modulated so that packaging materials that have a lower environmental impact will be the least expensive for producers to use. By introducing a modulated fee structure into the market, Defra has said that the use of unsustainable packaging materials will decrease.

The types of packaging which will be subject to higher or lower (modulated) fees from Year 2, and the consequential sub-categories of packaging that would need to be reported in 2025 are due to be released in Autumn 2024.

A Defra spokesperson said: “This government is committed to cracking down on waste as we move towards a circular economy.

“Extended producer responsibility for packaging is a vital first step. It will create 21,000 jobs, stimulate more than £10 billion investment in the recycling sector over the next decade, and see packaging producers, rather than the taxpayer, cover the costs of managing waste.

“We will continue to work closely with businesses on the implementation of this programme, and publishing the illustrative base fees provides them with the clarity they need to prepare.”