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PackUK issues first producer invoices under pEPR scheme

Packaging
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PackUK has issued the first Notices of Liability (NoL) to packaging producers under the Extended Producer Responsibility for packaging (pEPR) scheme.

The notices, distributed earlier this month, are based on 2024 packaging data reported by producers and cover the household waste disposal costs for April 2025 to March 2026.

PackUK published guidance on the invoicing and payment process, including instructions on how to view and settle invoices via the Report Producer Data (RPD) system.

The organisation has also highlighted the importance of payment security, warning producers to remain alert to potential fraud attempts.

Penalties for late payments

Under PackUK’s enforcement terms for the pEPR scheme, producers that miss payment deadlines could face a variable monetary penalty, calculated as the greater of:

  • 20% of unpaid fees
  • 5% of your UK turnover if registered as single organisation or 2% of your UK group turnover if registered as a group

Fees for packaging placed on the market in 2024 will be invoiced from October 2025.

PackUK has published base fees for EPR, providing the first official indication of expected waste disposal charges. The figures, described as “first estimates”, are based on current data and are expected to be refined ahead of finalisation.

Variable fees from 2026

The deadline for producer EPR data submissions passed on 1 October 2025, with all obligated large producers required to provide detailed information on their packaging volumes and recyclability classifications for the first half of 2025 (1 January to 30 June).

From 2026 onwards, EPR fees will vary depending on recyclability, as determined by PackUK’s Recyclability Assessment Methodology (RAM).

Packaging assessed as more recyclable will attract lower disposal fees, aligning financial incentives with environmental performance.

The methodology uses a red–amber–green (RAG) system to assess packaging materials and formats, with “green” denoting the most easily recycled.

PackUK published its RAM Roadmap 2025-2030 on 3 October 2025, setting out the expected timeline for milestones in pEPR guidance, deadlines and updates.


Interested in the latest insights, expert guidance, and practical strategies to navigate the new packaging EPR regulations? Come along to The EPR Conference on 12 November 2025 in London. Find out more and buy tickets here.

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