Three things manufacturers should do for Extended Producer Responsibility (EPR) by 2027. By Claire Robbins
Extended Producer Responsibility (EPR) is in its third year of reporting (the second with costs based on data submissions) – and the financial reality is materializing.
All 2025 data should have been reported. So, what should manufacturers be aware of in the remaining months of 2026?
A defining change this year is that fees will be modulated according to the Recyclability Assessment Methodology (RAM). Manufacturers must assess the sustainability of their packaging or face increased costs.
While EPR might seem a cost burden, it’s a fundamental change in how packaging is reviewed, reported on and what happens to it at end-of-life. This creates real opportunities for manufacturing businesses to think differently about the packaging they place on the market and prioritize recyclability, supporting their sustainability and financial goals.
To help you keep pace with this pivotal legislation, there are three actions that matter most.
1. Know your full liability (it’s now a need, not a ‘nice to have’)
EPR obligations depend on business size – these are the nuances to know…
You’re a small producer if you turn over between £1 million and £2 million and supply more than 25 tonnes of packaging annually in the UK. Or, if turnover exceeds £1 million and you supply 25-50 tonnes annually in the UK.
Small producers must report data but don’t need to pay household fees or PRN costs – only scheme and Environment Agency fees.
A large producer is any company that has a turnover of £2 million or more and handles 50 tonnes of packaging. These businesses must report every six months and will then have their associated costs (Packaging Recovery Note and PackUK fees) calculated.
A Packaging Recovery Note (PRN) is proof that packaging material has been recycled and reprocessed, rather than treated via energy recovery or landfill. A Packaging Waste Export Recovery Note (PERN) confirms it’s been exported for reprocessing. It’s common for manufacturers to think they either pay PRN costs or PackUK fees. But some must pay both, depending on whether they are handling household or non-household packaging. Yearly costs vary based on volume and type of packaging but can range from £1,000 to £50 million.
Ultimately, PackUK doesn’t charge for PRNs, only household fees. It’s the compliance schemes that do – they buy to offset producers’ legal obligation.
So, why is this timely? Large producers will soon receive their second Notices of Liability (NOLs) – the first NOL based on fee modulation – from PackUK. If you haven’t audited your packaging chain and quantified your full liability, that bill might come as a surprise – that’s where a partner like Biffa can help.
2. Complete your RAM assessment
The Recyclability Assessment Methodology (RAM) is a major development within EPR. Producers handling household packaging must complete recyclability assessments using a red, amber, green rating. The result determines your modulated fee. The price is then multiplied by the tonnage per packaging type. The more recyclable your packaging, the less you pay.
The RAM is updated annually – and this will be an ongoing challenge. Manufacturers that engage with a scheme and the RAM can effectively review the packaging specifications and work with their supply chain, mitigating a future of increased costs.
It can feel a big responsibility on top of day-to-day operations. But reassuringly, a compliance scheme partner will alleviate the burden by equipping you with packaging expertise and accurate, robust reporting.
Ultimately, the RAM is there for good reason: to help producers make more informed choices about sustainable packaging. Harnessing data lets you assess where you are, identify packaging rated ‘red’ or ‘amber’ – which will therefore cost your business more – then identify alternative materials that make commercial and sustainable sense.
Finally, the framework is still very much evolving. Further material-based specific reviews run through to 2030. Manufacturers who evaluate and optimize now will be better positioned.
3. Get your data right for October
EPR fees are calculated based on the data you report on – so accuracy is crucial. If the last deadline (April) passed you by, and you aren’t registered with a scheme, engage a compliance partner as a priority. They’ll support you through the process.
The next legal reporting deadline for schemes and direct registrants is 1st October 2026, with data submission required (with RAM assessments) by the end of August 2026. After that, the reporting cycle happens every six months: April (for the previous July-December) and October (for January-June).
This legislation is complex, requiring targeted and accurate data capture and reporting. Your numbers might be pulled manually and sit in spreadsheets – a process that’s time-intensive, prone to error and easily de-prioritized amid other pressures.
But incorrect data is not only a compliance issue – it’s costly and, at worst, could lead to reputational damage. That’s where we come in. We understand how packaging moves through the system, the capability of the UK recycling and reprocessing infrastructure, and the changing landscape of legislation. Unlike a standalone compliance scheme partner, we manage waste streams and reprocess plastic, providing a practical understanding of how packaging decisions play out.
It’s our job to help you report correctly, consistently and compliantly – turning a sizeable administrative burden into a manageable one. We’ll also ensure you submit in-line with deadlines and clearly understand the requirements.
EPR might be complex, but it is driving clearer accountability across the value chain. Early action means you won’t just avoid penalties but also make smarter packaging decisions that reduce costs over time – good news for your sustainability strategy and bottom line.
Claire Robbins
Claire Robbins is Head of Producer Compliance at Biffa. With over 100 years of expertise, Biffa is an established leader of sustainable waste management in the UK. Its purpose is to change the way people think about waste and its team of 11,000+ key workers provide unrivalled end-to-end waste and recycling solutions for thousands of businesses, and millions of households, each day.
