UK Packaging EPR 2026/2027: What Ecommerce Brands Need to Know

What EPR packaging means for an ecommerce business

Extended Producer Responsibility for packaging shifts more of the cost of dealing with packaging waste onto organisations that place packaging on the UK market.

For an ecommerce business, that can involve much more than the retail packaging around the product.

Official guidance defines packaging broadly as material used to contain, protect, handle, deliver or present goods. Ecommerce fulfilment can therefore bring shipping cartons, mail bags, cushioning and other shipment packaging into the reporting picture when the business is responsible for that packaging.

First check whether your business is actually in scope

A UK-established organisation generally becomes an obligated producer when it carries out an applicable packaging activity, supplied or imported more than 25 tonnes of packaging in the relevant previous year, and has annual worldwide turnover above £1 million.

For 2026 reporting, GOV.UK EPR guidance says organisations should assess packaging supplied or imported between 1 January and 31 December 2025 and use the relevant annual accounts when determining turnover.

That does not mean every business above £1 million automatically has the same responsibilities.

Small producer thresholds

A small producer can include an organisation with turnover above £1 million that supplies more than 25 tonnes of packaging but does not meet the large-producer threshold.

Small producers can have registration and reporting duties, but their financial obligations differ from those of large producers.

Small does not mean exempt

Businesses should not assume that falling below the large-producer threshold removes every EPR responsibility. Small producers can still need to collect packaging data, register and submit required information.

Large producer thresholds

A business is classed as a large producer where it has more than £2 million annual turnover and is responsible for more than 50 tonnes of packaging.

Large producers have broader obligations, including more frequent reporting and, where applicable, recycling obligations and household packaging waste disposal fees.

The regulatory labels refer to thresholds

The words “small” and “large” in EPR guidance refer to the regulatory turnover and packaging-tonnage thresholds. They do not refer to the number of employees in the business.

Which ecommerce packaging can count under EPR?

Packaging does not stop at the product carton.

Large-producer reporting guidance separates packaging into primary, secondary, tertiary and shipment classes.

Shipment packaging matters

Shipment packaging is particularly relevant to ecommerce.

GOV.UK defines shipment packaging as tertiary packaging used on products supplied, or intended to be supplied, to a consumer. The guidance gives examples including cardboard boxes, carrier bags, bubble wrap and mail bags.

That means packaging added during ecommerce fulfilment can matter separately from the packaging in which the product was originally manufactured.

A single order can contain several reportable components

A cosmetics order, for example, could include a retail carton around a bottle, a corrugated ecommerce box around the order and protective material inside the shipment. Those components may need to be classified and recorded according to the organisation’s actual EPR responsibilities.

Businesses using custom mailer boxes, cardboard boxes or other ecommerce packaging should therefore keep component specifications and weights organised rather than treating the complete shipment as one undifferentiated item.

Who is responsible for reporting the packaging?

Responsibility depends on what the organisation actually does with the packaging.

Relevant packaging activities include supplying filled packaging under a brand, packing or filling packaging, importing packaging, supplying empty packaging, hiring or loaning packaging and operating an online marketplace.

A business can carry out more than one activity

An ecommerce brand may import finished goods, add shipment packaging in its own fulfilment operation and sell those products under its own brand. Each activity needs to be considered against the current regulations and guidance.

Branded filled packaging

For branded filled packaging, the brand owner may carry the reporting responsibility in circumstances set out in the regulations and official guidance.

Packaging filled by the ecommerce business

Unbranded packaging that an organisation fills can fall under the packing or filling activity.

Supplying empty packaging

Empty packaging suppliers have another important distinction. GOV.UK guidance explains when packaging supplied empty remains the responsibility of the supplier and when responsibility can sit with an applicable producer that fills, packs or brands it.

Online marketplaces can have separate responsibilities

Separate rules can apply where online marketplaces facilitate sales from non-UK sellers into the UK. Marketplace operators should therefore use the dedicated official guidance rather than assuming the overseas seller always carries the EPR responsibility.

Small and large producers do not have the same obligations

This is one of the most important distinctions for ecommerce brands.

A small producer generally needs to register, pay the relevant registration fee and collect and report required packaging data.

What small producers do not pay

Current GOV.UK small-producer guidance states that small producers do not have to pay household packaging waste disposal fees and do not have to buy Packaging Recycling Notes or Packaging Waste Export Recycling Notes.

Large producers have additional obligations

Only large organisations must obtain PRNs or PERNs where required to meet applicable packaging recycling obligations. Large producers may also have to pay household packaging waste disposal fees.

Why this distinction matters

For ecommerce owners researching EPR for the first time, this prevents two opposite mistakes: assuming a smaller obligated business has no reporting duties, or assuming every obligated producer must immediately pay the full disposal-fee regime.

Important EPR packaging UK deadlines for 2026 and 2027

Large producers report packaging data every six months.

Small producers report once a year. Packaging data covering 1 January to 31 December 2026 must be reported by 1 April 2027.

The current dates should be checked against the official packaging data reporting deadlines before each submission.

Reporting periods and assessment years are not the same thing

This distinction can be confusing. Packaging data is collected and reported for defined calendar periods, while disposal-fee discussions may refer to an EPR assessment year such as 2026/27.

Those two date systems should not be treated as interchangeable.

The immediate 2026 deadline

As of 27 September 2026, the next large-producer reporting deadline is 1 October 2026 for packaging supplied from 1 January to 30 June 2026.

Businesses should not wait until the submission date to calculate packaging weights or determine responsibility. Reliable packaging data needs to exist before the return can be prepared accurately.

What RAM means for packaging recyclability

RAM stands for Recyclability Assessment Methodology.

Large producers that must report recyclability data use RAM to assess relevant household packaging and packaging commonly disposed of in public bins.

Packaging is assigned a red, amber or green recyclability rating. These ratings can then influence household packaging waste disposal fees.

RAM in 2026

For packaging supplied during the 2026 reporting year, PackUK guidance says large producers should use RAM version 1.1.

A green rating generally represents packaging performing more favourably under the methodology, while red represents packaging with poorer recyclability performance. The actual assessment must follow the published methodology rather than a simple assumption based only on the main material.

Paper does not automatically mean green

A paper-based pack should not automatically be treated as green merely because the primary material is paper. Coatings, laminates, components and other design features can affect the assessment.

RAM 2027

RAM 2027 applies to relevant household packaging supplied during the reporting year from 1 January to 31 December 2027.

The methodology assesses recyclability through factors covering collection, sortation, reprocessing and end-use considerations while retaining the red, amber and green rating approach.

Packaging decisions made in 2026 can affect 2027 reporting

Brands reviewing packaging specifications in late 2026 should therefore consider whether design choices being approved now could influence the RAM result for packaging supplied during 2027.

How modulated disposal fees work

Fee modulation starts in the second EPR assessment year, 2026 to 2027.

The principle is that recyclability affects how household packaging waste disposal costs are allocated.

Red, amber and green fee treatment

PackUK’s modulation policy states that amber-rated packaging remains at the base household packaging waste disposal fee.

For red-rated packaging, the modulation factors are:

For the 2026/27 assessment year, the relevant disposal-fee element for red-rated household packaging is therefore increased by a factor of 1.2.

Green discounts are not simply fixed percentages

The additional revenue raised from red-rated packaging is redistributed through lower fees for green-rated packaging. The exact green reduction depends on the reported mix of red, amber and green packaging rather than being a permanent fixed discount.

The current approach is explained in the official PackUK disposal-fee modulation statement.

What is happening with 2026/27 fees right now?

There is an important timing issue around the Year-2 figures.

PackUK published illustrative Year-2 fees in December 2025 to help producers plan. Those figures were estimates rather than final charges.

Illustrative fees should not be described as final fees

The illustrative table included estimated green, amber and red rates for different packaging materials. Those numbers were specifically presented as estimates subject to change.

When confirmed Year-2 fees are expected

PackUK’s August 2026 operational plan indicates that confirmed Year-2 disposal fees are expected to be calculated in November 2026 after producer data has been received and checked by the environmental regulators.

Initial liability notice

PackUK intends to issue the initial notice of liability for the 2026/27 assessment year by the end of November 2026.

Businesses can use illustrative figures for planning context where appropriate, but they should be clearly labelled as illustrative until PackUK confirms the actual rates.

Paper and cardboard ecommerce packaging under EPR

For ecommerce brands using corrugated mailer boxes, postal boxes or cardboard shipping cartons, packaging weight matters because EPR data is reported by material and weight.

Current large-producer guidance lists paper or card as one of the reportable material categories. Packaging components can also need to be considered separately according to their material.

Keep reliable packaging specification data

A useful packaging record can include:

• box weight;
• material category;
• separate inserts or components;
• plastic or paper mailing materials;
• cushioning;
• labels or other packaging components where relevant;
• units placed on the market.

Repeated grams become tonnes at scale

Reducing unnecessary packaging weight can affect more than the purchase price of a box. Where the business is liable for tonnage-based EPR costs, unnecessary grams repeated across thousands of orders contribute to the overall packaging tonnage placed on the market.

However, lightweighting should not compromise the protection required for the product. Damaged goods and replacement shipments create additional material, transport and commercial costs.

What ecommerce brands should record internally

Good EPR reporting starts with product and packaging data that can be traced.

Build a packaging component record

A practical record can include the SKU, packaging component, material, component weight, supplier, structural specification, whether the packaging is household or non-household, packaging class and the relevant RAM result where required.

For ecommerce fulfilment, keeping shipment packaging separate from primary product packaging can also make analysis easier.

Track actual packaging use where practical

If one mailer size serves several products, record how many units of that mailer actually leave the business rather than relying only on purchase quantities without considering unused stock or packaging remaining in inventory.

Supplier specifications can support the process, but the obligated organisation remains responsible for the accuracy of the information it reports.

Packaging changes worth reviewing before 2027

EPR does not mean that every ecommerce brand should immediately replace its existing packaging.

It does create another reason to review packaging specifications carefully.

Questions worth asking about ecommerce packaging

• Is the box larger or heavier than the product requires?
• Can unnecessary components be removed?
• Are coatings, laminates or integrated materials affecting recyclability?
• Does an insert provide a genuine protection or presentation function?
• Can packaging weight be reduced without weakening transit performance?
• Can the supplier provide reliable material and component weight data?

Do not optimise for EPR in isolation

A lighter structure is not automatically better if it causes product damage, requires additional cushioning or performs poorly during transport.

For ecommerce brands reviewing custom mailer boxes and packaging materials, the useful objective is to remove unnecessary material while maintaining the protection and fulfilment performance the product genuinely requires.

Common EPR mistakes ecommerce brands should avoid

Checking turnover but ignoring packaging tonnage

Turnover alone does not determine EPR status. Packaging tonnage and the activities performed by the organisation also matter.

Forgetting ecommerce shipment packaging

Businesses may focus on the retail carton and overlook the mailer, shipping box or other material added when the online order is prepared for the consumer.

Assigning responsibility to the wrong organisation

Brand ownership, packing, importing, supplying empty packaging and operating an online marketplace can all affect who reports particular packaging.

Treating illustrative fees as confirmed

Planning figures should not be published internally or externally as final statutory charges unless PackUK has confirmed them.

Guessing recyclability from appearance

RAM is a defined methodology. A pack should not be categorised as green simply because it looks recyclable or because the main component is paper.

Use current official guidance when responsibility is unclear

Where the position is genuinely uncertain, businesses should use the current GOV.UK Extended Producer Responsibility for packaging guidance or obtain appropriate compliance advice instead of guessing.

FAQs about EPR packaging UK

Does EPR packaging apply to every UK ecommerce business?

No. Obligations depend on factors including whether the organisation is established in the UK, which packaging activities it performs, annual turnover and packaging tonnage. The general threshold begins above £1 million turnover and more than 25 tonnes of relevant packaging, but obligations then differ between small and large producers.

What should a smaller ecommerce business check first?

Check both turnover and the amount of packaging the organisation supplied or imported during the relevant period. Do not rely on turnover alone.

What is the large-producer threshold?

Current GOV.UK guidance classifies a producer as large where annual turnover is more than £2 million and the organisation is responsible for more than 50 tonnes of packaging.

Why does large-producer status matter?

Large producers have additional requirements, including six-monthly packaging-data reporting and, where applicable, recycling and household packaging waste disposal-fee obligations.

Do small producers pay EPR disposal fees?

No. Current official guidance states that small producers do not have to pay household packaging waste disposal fees and do not have to buy PRNs or PERNs. They can still have registration, fee and packaging-data reporting duties.

Do ecommerce shipping boxes count as packaging?

They can. GOV.UK recognises shipment packaging used to supply products to consumers and gives examples including cardboard boxes, mail bags, carrier bags and bubble wrap.

What about protective packaging inside the box?

Protective components can also form part of the packaging system and may need to be classified according to the organisation’s EPR responsibilities.

What is the next EPR reporting deadline in 2026?

For large producers, the next reporting deadline is 1 October 2026 for packaging data covering 1 January to 30 June 2026. The next deadline covering July to December 2026 is 1 April 2027.

What is changing with EPR fees in 2026/27?

2026/27 is the first assessment year in which household packaging waste disposal fees are modulated according to RAM recyclability ratings. Red packaging attracts an increased fee element, amber remains at the base rate and green packaging receives a corresponding reduction through the modulation system.

Are the Year-2 £/tonne figures final?

Not yet as of 27 September 2026. Earlier Year-2 values were illustrative. PackUK’s current operational timetable expects confirmed Year-2 fees to be calculated in November 2026.

Which RAM version applies in 2027?

RAM 2027 applies to relevant packaging supplied during the 2027 reporting year. RAM version 1.1 remains the methodology used for the 2026 reporting year.