Packaging EPR Fees in 2026: What Caterers Should Know

Packaging extended producer responsibility (EPR) entered its second year in 2026-27, and this is the year the fees stop being flat. From 2026-27, what a producer pays per tonne depends on how recyclable the packaging is, rated red, amber or green. PackUK plans to calculate year 2 disposal fees and issue the initial notice of liability by the end of November 2026. Most catering businesses are too small to be billed directly, but the packaging they buy sits upstream of those fees, which is why disposable serviceware, pots, lids, trays and cups have been repriced across the sector.

Who actually pays packaging EPR

This is the part most often got wrong, so it is worth being precise. According to GOV.UK guidance on who is affected , last updated on 11 June 2026, an organisation has to collect and report packaging data if all of the following apply: turnover of £1 million or more, more than 25 tonnes of packaging supplied or imported in the previous calendar year, and carrying out a packaging activity.

Within that, there are two sizes:

• Small organisation — turnover over £1 million while supplying or importing between 25 and 50 tonnes, or turnover between £1 million and £2 million with more than 25 tonnes.
• Large organisation — turnover of £2 million or more and more than 50 tonnes of packaging.

Only large organisations pay the waste disposal fee, along with scheme administrator costs and a registration charge. Small organisations have data-recording and reporting duties but not the disposal fee.

Twenty-five tonnes is a great deal of packaging. An independent catering business, even a busy one working festivals and large private events, will usually fall under the threshold entirely. The fees still reach it, because the manufacturers and wholesalers supplying that packaging are frequently well over both thresholds, and the disposal fee is a cost in their pricing.

One definitional point catches food service directly. The GOV.UK guidance confirms that packaging includes “anything that’s designed to be filled at the point of sale, such as a coffee cup”, and that placing goods into packaging can trigger obligations whether done for your own organisation or another. Hiring or loaning reusable packaging, and supplying empty packaging, are also listed activities.

Year 2 is when recyclability starts changing the bill

The mechanism is set out in the PackUK producer disposal fees modulation statement , dated 28 June 2025 and published on GOV.UK on 17 February 2026.

Recyclability is assessed using the Recyclability Assessment Methodology (RAM), which rates each item red, amber or green. The statement explains that:

• red-rated material has its disposal fee multiplied by a modulation factor, raising it;
• the extra revenue goes into a redistribution pot;
• green-rated material receives an equal percentage discount across all material categories;
• amber-rated material is unchanged;
• modulation does not increase the total fees collected — it reallocates them between materials.

Modulation starts in year 2. The first modulated fees apply to 2026-27 and are calculated using 2025 packaging data. The red modulation factor tightens over time: 1.2 in 2026-27, 1.6 in 2027-28 and 2.0 in 2028-29. Ratings are self-reported, and environmental regulators will check they are accurate.

That escalation is the point: a red rating costs a fifth more this year and twice the amber rate by 2028-29, which is a strong reason for suppliers to redesign rather than absorb.

The illustrative figures published so far

PackUK published year 2 illustrative waste disposal fees on 16 December 2025, updated on 19 December 2025. They are indicative and expressly “subject to change as more information becomes available”.

Comparing the year 1 (2025-26) base fee with the year 2 amber rate, in £ per tonne:

Year 2 red fees are 20% above amber, and the green discount is provisional at around 9%. Two lines matter most for food service. Fibre-based composite, the category covering many lined cups and board containers, carries the highest amber rate in the table at £525 per tonne. Wood rose furthest, which PackUK’s figures put at 60% above the year 1 base — relevant to wooden cutlery, stirrers, skewers and crates.

These remain illustrative. The modulation statement says base fees will be published as they become available, and final modulated fees once all data is reported.

The dates between now and spring 2027

The PackUK operational plan for 2026 to 2027 , first published on 27 February 2026 and last updated on 10 August 2026, sets out the scheme’s own timetable. It published the next recyclability assessment methodology, RAM 2027, on 1 July 2026. It stopped recalculating notices of liability for producers resubmitting data after 1 September 2026. And it plans to calculate year 2 disposal fees and issue the initial notice of liability by the end of November 2026.

The plan forecasts total fee recovery of £1.558 billion for 2026-27, comprising £1.47 billion in disposal fees, £28 million in administration fees and £60 million impairment.

On reporting, the GOV.UK deadlines guidance , last updated on 19 August 2026, confirms that large producers reported 1 January to 30 June 2026 data by 1 October 2026, and must report 1 July to 31 December 2026 data by 1 April 2027. Small producers report the full 2026 calendar year by 1 April 2027.

Any business near the thresholds should check its position against those dates rather than assume it is out of scope, because the test applies to the previous calendar year.

Next on the timetable: the deposit return scheme

For anyone serving drinks at events, the other change worth diarising is the deposit return scheme. GOV.UK guidance on producer and retailer responsibilities states the scheme launches on 1 October 2027, covering single-use containers made wholly or mainly from aluminium, steel or PET plastic, between 150 millilitres and 3 litres. HDPE containers, such as milk bottles, are excluded.

The guidance sets out a specific position for hospitality. Venues selling drinks for consumption on the premises can choose not to charge the deposit at the point of sale, provided they display clear opt-out information and ask customers to leave empty containers behind. A venue also selling takeaway drinks may apply the deposit only to those takeaway sales, and hospitality venues can apply to become voluntary return points. Product lines of fewer than 5,000 units a year are exempt from producer fees, deposits and labelling, but must still register and report volumes.

The deposit amount is not fixed in that guidance; the deposit management organisation sets it. The page’s visible update date is 30 January 2025, so check it again closer to launch.

Frequently asked questions

Does a small catering business have to register for packaging EPR? Not unless it meets the thresholds: turnover of £1 million or more, more than 25 tonnes supplied or imported in the previous calendar year, and a packaging activity. The disposal fee applies only to large organisations — £2 million or more turnover and more than 50 tonnes.

Are disposable cups and food containers in scope? The GOV.UK packaging definition includes anything designed to be filled at the point of sale, giving a coffee cup as the example. Whether that creates an obligation depends on the thresholds and the activity carried out.

Why has packaging got more expensive if modulation is revenue-neutral? Modulation reallocates rather than increases total fees. The increases in the year 2 illustrative figures sit in the base rates, and those remain indicative rather than final.

What should be checked before the 2027 season? The confirmed 2026-27 fees, RAM 2027 ratings for lined-board, composite and wooden items, the 1 April 2027 reporting deadline for anyone in scope, and the deposit return scheme ahead of 1 October 2027.