Most organisations meet extended producer responsibility for packaging as a data request. Someone asks for tonnages by material, split in ways the business has never recorded, with a deadline attached. The request feels administrative. It is not. It is the end of a chain that began when somebody chose a laminated pouch over a mono-material film, or specified a heavier carton because it looked better on shelf.
That is the useful way to think about EPR. Where an organisation meets the relevant producer role and thresholds, it can convert packaging choices into recurring fees and reporting obligations, and it asks that organisation to describe those choices in detail. What any individual business actually pays, and whether it pays at all, depends on its role, its size and the obligations that follow.
First check the role, not the packaging
A predictable error is assuming that buying a lot of packaging makes you obligated. Obligation under the UK regime depends on whether you meet a defined producer role, such as brand owner, packer or filler, importer, distributor, online marketplace or service provider, along with turnover and packaging tonnage thresholds. Government guidance sets out those roles and thresholds and should be the starting point for any internal assessment.
This matters commercially. A contract packer and the brand whose name is on the pack do not carry the same responsibility, and a supplier switch can move an obligation between organisations without anyone intending it. Before building a data programme, establish which entity in your group holds which role, and for which product lines.
Source: GOV.UK, check if you must comply with extended producer responsibility for packaging
The data is component level, and your systems probably are not
The useful unit to hold data in is not the pallet or the case. It is the component: the tray, the film, the label, the outer, the pallet wrap. Each needs a material category and a weight, and each needs a household or non-household classification determined by the official rules and the evidence behind them, rather than by an internal view of where an item is likely to end up. A single finished product can easily carry six components sourced from three suppliers.
A component register is the recommended basis for aggregation and reporting. That is not a claim that every component of every SKU is reported individually. You report in the categories and at the level of detail the applicable scheme requirements set out, and a clean component register is what lets you produce those figures without rebuilding the data each year.
Purchase ledgers rarely hold any of that. They hold a supplier, a description, a quantity and a price. The gap between the two is where most EPR programmes stall, and it is why the answer is not a better spreadsheet at year end but a data requirement written into specification and purchasing.
Recyclability is becoming a price signal
Alongside reporting, the regime modulates what obligated producers pay according to how recyclable their packaging is, assessed through the Recyclability Assessment Methodology. For the 2026 assessment, the applicable methodology is RAM version 1.1. Separate guidance has been published for the 2027 assessment, and the linked 2027 page itself confirms that it does not apply to 2026. Use the version in force for the year you are assessing, and treat the later document as a forward look rather than as your current method.
We are deliberately not quoting fee figures here. They change, and a stale number in a board paper is worse than no number. What is stable is the direction: the harder your packaging is to recycle at scale, the more likely it is to cost you more, and the change that reduces that cost is usually made at design stage, not at reporting stage.
Source: GOV.UK, assess packaging recyclability (Recyclability Assessment Methodology, 2027)
Whole cost, not unit price
A packaging decision now carries at least four costs: the purchase price, the fee exposure that follows from its material and recyclability, the handling and disposal cost when it reaches a site, and the reporting effort required to describe it. Buying teams are usually measured on the first only.
Bringing the other three into the comparison changes outcomes. A slightly more expensive mono-material film that is accepted in an existing recycling stream, weighs less and needs no separate classification argument can be the cheaper option once all four costs are counted.
A workable sequence
- Confirm which legal entity holds which producer role, and evidence that assessment.
- List every packaging component reaching the market under your brand, not just the ones you buy directly.
- Add material, component weight and a household or non-household classification to your specification template, applying the official classification rules and recording the evidence for each decision.
- Make that data a condition of supplier set-up and of any specification change, with a revision date.
- Reconcile reported tonnage against purchase volumes annually and investigate the differences rather than smoothing them.