Producer pEPR Fees & Invoice Resubmissions
On 14 October 2025, the UK packaging EPR scheme reached a major milestone with the issue of the first Notices of Liability (NoLs) to obligated producers. These invoices, which formally shift the cost of collecting and sorting packaging waste from households to producers, are a foundational element of the pEPR regime.
How the base fees are calculated
The calculation of pEPR base fees relies on two key components.
1) Local authority waste management costs
The LAPCAP model, developed by Defra, is used to calculate how much each UK local authority spends managing household packaging waste, net of any revenue generated from the sale of collected materials.
When these net local authority costs are aggregated across the UK and combined with each material’s share of additional scheme costs (including PackUK administration, communications, and debt provision), they form the total amount that must be recovered from producers under pEPR.
2) Producer-reported packaging tonnages
Producers submit data twice yearly, reporting the tonnage of household and public bin packaging they place on the market. These submissions are aggregated to give a total tonnage for each packaging material.
Dividing the total cost to be recovered (1) by the total reported tonnage (2) produces the base fee, the per-tonne cost of managing each material.
What happened in practice
When the 2025 base fees were published in June 2025, the compliance year had not yet closed, and not all producers had completed their submissions. To account for this, Defra used an analytical model to estimate the total in-scope packaging likely to be reported, alongside completed H1 and H2 2025 data.
This model was subject to external quality assurance by the Government Actuary’s Department, and the methodology to adjust for unreported packaging data was reviewed by senior analysts across the UK governments.
While the modelling was appropriate based on the information available at the time, the issuance of NoLs in October triggered a significant wave of resubmissions. Many producers revisited their data once they could see the direct financial implications, leading to revised figures that were materially lower than the government’s projections.
Why fees may now increase
The 2025 compliance year is now closed, and no further submissions can be made. The total reported tonnage is therefore fixed.
If we look back to the original calculation:
- the total cost to be recovered (local authority and scheme costs) has not changed; however,
- the total tonnage has decreased.
As a result, the per-tonne base fees must increase to ensure the required total is still recovered. This reflects the zero-sum nature of pEPR: the scheme cannot raise more or less than the actual costs incurred.
What happens next
Because this was the first NoL and the first time many producers experienced the full financial impact of pEPR, a surge in resubmissions was perhaps inevitable. A positive interpretation is that producers undertook detailed reviews of their data to improve accuracy, rather than deliberately understating tonnages to reduce costs – behaviour that would undermine the scheme.
Looking ahead to 2026, it is reasonable to expect fewer large-scale resubmissions as producers refine data collection and reporting processes, multiple years of data are inputted into the system, and government methodologies continue to be refined. Over time, this should lead to greater stability between illustrative fees, base fees, and any potential post-submission adjustments.
The past few years have been challenging for businesses, and the introduction of significant packaging reform has added further complexity. There are clearly lessons to be learned around methodology, communication, and implementation. However, these are early-stage issues. In the longer term, pEPR has the potential to drive better packaging design, lower system costs, and a more circular economy… once the initial teething problems are resolved.
Timeline
- February = Recalculation of 2025 (Y1) NoL
- March 3 = Second DD payment. If you haven’t paid in full and don’t have a DD payment plan set up, please contact PackUK before this payment is due
- April = 2026 (Y2) base fees to be published
- June = Y2 NoL to be sent to relevant producers
Beyondly is here to help!
Environmental policy is constantly evolving, with global efforts driving us toward a more sustainable circular economy. At Beyondly, we keep our members informed of key regulatory changes and emerging developments. By sharing timely insights, we empower you to make confident, informed decisions that align with the shifting environmental landscape.
If you have any questions regarding producer pEPR fees and invoice resubmissions, please do not hesitate to contact your dedicated Account Manager who is always on hand to help.
