Spring 2025 EPR policy round up

There have been numerous policy updates relating to packaging EPR, here’s the essentials you need to know.
Fee modulation in 2026
Defra shared in a recent ‘Joint Stakeholder Forum’ an example of how EPR fee modulation, starting in 2026, may look for the first three years. The indicative modulation rates charge packaging that is assigned as ‘red’ via the Recyclability Assessment Methodology (RAM) at a rate higher than the material base fee – 1.2 times the fee in 2026, 1.6 times in 2027, and double by 2028. The illustrative base fees per material were announced in December 2024.

As an example, the estimated base fee for plastic for this year is currently £485, meaning producers may pay around £970 per tonne for hard to recycle plastic packaging formats in a few years. Packaging formats assigned as ‘green’ will then be decreased relative to the total amount of ‘red’ packaging, to be confirmed each year, and ‘amber’ packaging will likely be invoiced at the base fee rate.
The first EPR submission that includes RAM ratings will be in October this year, meaning there will be a better understanding of the total amount of packaging assigned ‘red’ and therefore the ability to make more informed estimations of costs. Until then, alongside working towards gathering all the information needed to complete the recyclability assessments, producers should start considering moving away from hard to recycle packaging formats, to avoid annually increasing costs under the modulation system.
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