pEPR Update: 2026 illustrative disposal fees v.1 announced
It’s been a turbulent year (or two) for producers under the new pEPR regulations. Thankfully the first milestone was passed in October 2025 with the first Notices of Liability (NoL) being sent to relevant producers containing the costs they need to pay for the household, and public bins, packaging they put onto the market in 2024.
We are now at the end of 2025, producers have submitted their Jan-Jun (H1) 2025 data submission and PackUK, on 16 December 2025, published illustrative disposal fees for this packaging, ahead of final confirmation after April 2026 and the issuing of Notices of Liability (NoLs) later that year.
Illustrative 2026 pEPR fees v.1
These fees are rounded to the nearest £5, and are subject to change
These figures have been calculated using the modelling for Y1 fees to reduce disruption. The data used from producers H1 2025 data submissions and has been extrapolated for the whole year based on previous years’ data to account for seasonal changes.
You’ll notice that the fees have increased for a couple of reasons. Firstly, costs have been increased to account for inflation, and secondly, there was a decrease in total reported tonnage, especially taking into account resubmissions after the Y1 NoL.
The last thing to note on these illustrative fees, before we move onto modulation, is that you may start to see the fees for plastic being split out into ‘rigid’ and ‘flexible’. For invoices raised in 2027, there will be separate fees for these two subcategories of plastic, but for these fees those materials will attract the same fee.
Modulation
For red material, as stated before back in June, there is a flat 20% increase for all materials, which will increase year on year in line with the Modulation statement.
Amber fees are calculated in the same way as base fees were calculated in Year 1, based on the total costs incurred and expected total submitted tonnages.
Green fees are trickier to estimate at the moment as the final fee will be dependent on both the final base / amber fee, and the percentage of red material that is placed on the market. These figures represent a 9% decrease from the base fee and are based on the current data available. Because this fee is based on multiple variables it is more subject to change.
Why are these fees being released?
There are multiple variables that go into the calculation of these fees, that mean we won’t see illustrative or final costs until the data has been submitted. The fees are based on the costs incurred by Local Authorities for the managing of waste, along with the total packaging that was placed on the market. Because producers don’t submit their packaging data until April, after packaging has been placed on the market, we won’t see final costs until after that date.
In terms of forecasting, it’s too early to draw any long-term conjecture on the future of these fees for the coming years for two reasons;
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Firstly, these are just the first peek of illustrative fees, and if we learnt anything from the previous year, these may be subject to a handful of iterations before we see the final fees around June time.
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Secondly, this is still only the second year of fees under the pEPR system. We are going to need a good couple of years under our belts to draw any conclusions and find any patterns in the data for companies to forecast against.
One of the tricky things for businesses during this change of regulation has been forecasting, and last-minute updates and changes throughout the process hasn’t helped this fact. Hopefully, now that we have the first batch of NoL sent out, and these new illustrative fees, along with the dust settling around pEPR and ‘normality’ setting in, we will start to see a pattern emerging that will help producers to start looking to the future, making amendments to packaging where needed, and forecasting appropriately.
Beyondly members - your Account Manager and our wider Packaging Team are on hand to help you digest all changes presented during the establishment or the new pEPR Regulations and help you prepare for future submissions. If you have any queries or would like to discuss this further, please contact your Account Manager or drop an email to [email protected].
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We look forward to continuing to help you navigate the pEPR Regulations now and in the future.
