PackUK release illustrative year 2 waste management fees

Illustrative waste management fees for the 2026 compliance year, including the first look at the impacts of eco-modulation, were published on 16 December by PackUK.
The fees will apply to eligible packaging placed on the market by liable producers in 2025, and will be charged in the 2026/27 financial year. The fees cover the cost of collecting and recycling packaging waste by local authorities and are entirely separate from recycling (PRN) obligations.
Crucially, year 2 fees will be eco-modulated according to the Recycling Assessment Methodology (RAM).
The illustrative year 2 waste management fees are as follows:

The amber fee is essentially the ‘base fee’. The red fee is calculated at 1.2x the amber fee. The green fee is variable and based on the volume of red-rated packaging. PackUK have estimated the ‘green discount’ to be 9% (i.e. 0.91x the amber fee).
While the amber fees are broadly similar to the 2025 ‘base fees’, wood has increased by 60% (from £280 per tonne in 2025 to a 2026 amber fee of £450 per tonne).
The fees have been projected using the most recent data submitted by large organisations to the EPR Report Packaging Data portal, and the local authority waste management costs modelled using Defra’s Local Authority Packaging Cost and Performance model (LAPCAP). The modelling also includes an inflationary increase to ensure full net cost recovery.
PackUK also published the relative proportions of red, amber and green packaging from the 2025-H1 data submission:

This is similar to what Ecosurety were predicting and in line with what our members are submitting. Indeed, we had previously estimated the ‘green discount’ to be 9% in year 2.
Final fees coming in June 2026
The final fees will be confirmed in June 2026, following the regulatory deadline for submitting data on packaging supplied in 2025.
“While these fees are a step in the right direction, they are far from the finished article. It does, however, signify that the Government are serious about punishing badly designed packaging. The indicative fees will help companies begin to plan and adjust their budgets for potentially higher costs next year. The bigger picture is that the packaging data from producers will get more accurate and granular over time causing PackUK to become increasingly confident about the penalties they should deal out. We expect the Recyclability Assessment Methodology to evolve in line with the roadmap published earlier in the year. The Technical Advisory Committee have their work cut out to improve the methodology in line with the Government's increasing penalties.”

Robbie Staniforth
Innovation and Policy Director, Ecosurety
EPR cost modelling for Ecosurety members
Our EPR cost modelling analytics tool in the Ecosurety Hub has been updated so that our members can model the impact of eco-modulation on their compliance costs. This is available for Advanced and Premium members.
If you have any questions in the meantime, please contact our team.

by Matthew Austin
Lead Market Analyst
15 December, 2025
Matthew is our Lead Market Analyst, focused on delivering impactful data reporting that will add value and drive change, both internally and for our clients.
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