Extended Producer Responsibility fees are per-tonne charges a business pays on the packaging it places on the market, calculated by multiplying the weight of each material by that material’s published rate and then adjusting the result up or down based on how easily the packaging can be recycled. EPR fees are not a sales tax and not a flat percentage. They are cost-recovery charges that shift the price of collection, sorting, and recycling from local governments to the companies whose products create the waste. A producer using lightweight cardboard pays a very different amount than one using multi-layer plastic pouches, and the rate changes again depending on the jurisdiction where the product is sold.
How the Calculation Works
The core formula is simple. Total weight of packaging placed on the market, multiplied by the applicable rate per tonne for that material category, gives the fee for that material. A producer selling 500 tonnes of glass packaging in a jurisdiction charging £205 per tonne would owe roughly £102,500 for that material stream alone. The calculation runs separately for each material type, so a single product with a cardboard box, a plastic film insert, and a steel clasp generates three separate fee lines.
Rates reflect real recycling economics rather than policy preferences. Fee-setting bodies divide the total cost of managing each waste stream (collection, sorting, and processing, minus revenue from selling recovered material) by the total weight of that material placed on the market.1GOV.UK. Extended Producer Responsibility for Packaging: 2025 Base Fees When secondary markets for a material are strong and the recovered resource fetches a good price, the net cost drops and so does the fee.
What Each Material Costs
Material choice is the single biggest lever on your total. The UK’s EPR program publishes one of the clearest fee schedules available. Its 2025–2026 base fees per tonne of household packaging are:1GOV.UK. Extended Producer Responsibility for Packaging: 2025 Base Fees
- Glass: £192 per tonne
- Paper and card: £196 per tonne
- Steel: £259 per tonne
- Aluminium: £266 per tonne
- Wood: £280 per tonne
- Plastic: £423 per tonne
- Fibre-based composite: £461 per tonne
Glass and paper sit at the bottom because established recycling streams exist for both and recovered material sells readily. Plastic costs more than double glass, largely because sorting by resin type is expensive and secondary markets for many plastic grades remain weak. Fibre-based composites (juice cartons with layers of paper, plastic, and aluminum bonded together) top the list because separating those layers is technically difficult and sometimes impossible at scale.
Illustrative rates for the second UK program year (2026–2027) show modest increases across most categories: glass rises to roughly £205 per tonne, paper and board to £210, plastic to £455, and fibre-based composite to £525.2GOV.UK. Year 2 Illustrative Waste Disposal Fees: Extended Producer Responsibility for Packaging Rates tend to climb as programs mature and the true costs of waste management become clearer, so producers should expect upward pressure over time rather than stable fees.
Sub-types within a category matter too. Clear PET bottles are among the easiest plastics to recycle and tend to attract lower fees than colored or flexible plastics. Multi-layer laminates, black plastic trays, and packaging with non-removable labels all drive costs higher.
Eco-Modulation: Rewards and Penalties on the Base Rate
Base rates are the starting point. Most programs then apply eco-modulation, which rewards packaging designed for easy recycling and penalizes packaging that complicates the process.3OECD. Extended Producer Responsibility: Basic Facts and Key Principles
On the reward side, a producer that adds post-consumer recycled content, reduces total material weight, or designs for easy disassembly can earn a lower per-tonne rate. In the UK, “green”-tier glass drops to £185 per tonne against the £205 amber (base) rate, and green-rated aluminium falls to £245 from a £270 base.2GOV.UK. Year 2 Illustrative Waste Disposal Fees: Extended Producer Responsibility for Packaging
Penalties run the other way. “Red”-rated plastic jumps from £455 at the base rate to £545 per tonne, and fibre-based composites climb from £525 to £630.2GOV.UK. Year 2 Illustrative Waste Disposal Fees: Extended Producer Responsibility for Packaging Packaging with toxic inks, problematic adhesives, or materials that interfere with optical sorting equipment typically lands in the highest penalty tier. Programs tend to widen the gap between green and red rates as they mature, so designing for recyclability now pays off increasingly over time.
Who Actually Owes the Fee
EPR laws cast a wider net than many business owners expect. The “producer” is usually not the company that manufactures the packaging. In most jurisdictions, the obligation falls on the brand owner whose name appears on the product. If you import goods into a covered jurisdiction under your own brand, you are the producer for EPR purposes, even if a contract manufacturer overseas made both the product and its packaging.
Where no brand owner exists in the jurisdiction, responsibility typically shifts to the first company that places the packaged product on the market there. That could be an importer, a distributor, or a retailer selling unbranded or private-label goods. Online sellers shipping into a state with EPR obligations face the same rules as brick-and-mortar retailers. If your packaged product reaches a consumer in a covered jurisdiction, the program likely considers you a producer regardless of where your business sits.
Small Business Exemptions
Not every business that sells packaged goods owes EPR fees. Most jurisdictions carve out exemptions for small producers based on annual revenue, tonnage of packaging placed on the market, or both. Revenue thresholds generally fall between $1 million and $5 million in gross annual sales, and tonnage thresholds are often set at one tonne or less of covered materials per year. A business below either threshold is typically exempt from registration and fee obligations, though the exact cutoff varies.
Some programs also exempt nonprofit organizations. These exemptions are not permanent. A growing business can cross a threshold from one year to the next, triggering full registration and fee obligations. Annual self-assessment is the only way to stay current, because ignorance of a threshold change is not a defense against non-compliance penalties.
EPR in the United States
There is no federal EPR mandate, and none appears imminent. Seven states had enacted EPR packaging laws as of early 2026, each at a different stage of implementation. Some began collecting producer fees in 2025 or early 2026, while others are still conducting needs assessments and finalizing program rules. A company selling nationwide could owe fees in multiple jurisdictions at different rates while owing nothing in states without EPR legislation.
Most state programs designate a Producer Responsibility Organization, a nonprofit that producers join and pay into, which then manages collection and recycling logistics and reimburses local governments. In several states, one organization serves as the designated PRO across multiple jurisdictions, allowing producers to register and report through a single portal. That simplifies paperwork, but fee schedules still differ by state because each program’s costs depend on local recycling infrastructure, transportation distances, and processing capacity. A producer’s per-tonne rate for the same material can vary meaningfully from one state to the next.
Registration and Reporting Deadlines
For the 2026 reporting cycle, several states have aligned annual supply report deadlines around the end of May 2026. Producers in states with active programs generally need to submit data on the total weight of each packaging material type placed on the market during the prior calendar year. Some states require a full annual supply report; others accept a simplified version for smaller producers. One state has indicated its reporting deadline will fall later, in the third quarter of 2026.
Registration portals for the current cycle opened in late March and April 2026. Producers who have not yet registered with their assigned PRO should check their obligations promptly. Late registration does not eliminate the obligation to pay fees for the full reporting period, and most programs assess the obligation retroactively to the date the producer first met the definition of a covered entity. Waiting until a fee invoice arrives is a common and expensive mistake.
Penalties for Non-Compliance
EPR laws carry real enforcement teeth. Penalties for failing to register, underreporting packaging data, or missing payment deadlines can reach tens of thousands of dollars per violation. Some jurisdictions escalate penalties sharply for repeat offenses, with successive violations potentially costing up to $100,000 per day in the most aggressive structures. Even first-time violations can trigger fines in the low thousands.
Beyond direct fines, non-compliant producers risk being barred from selling products in the jurisdiction until they come into compliance. Public listing as a delinquent producer adds a reputational cost, particularly for consumer-facing brands. Enforcement mechanisms are still being stood up in most U.S. states, and producers who establish clean compliance records now will be better positioned than those scrambling to catch up after an audit.
Data You Need to Run the Numbers
Calculating your total liability requires detailed packaging data that many businesses do not routinely track. At minimum, you need the precise weight of every material type used in each layer of your packaging: primary packaging that touches the product, any secondary packaging like a retail-ready box, and tertiary packaging such as shrink wrap or shipping pallets used for bulk transport.4GOV.UK. Packaging Data: What to Collect for Extended Producer Responsibility A single product might involve four or five distinct materials across those layers, each generating its own fee line.
You also need accurate sales volume data broken down by jurisdiction. Selling 10,000 units nationally is not enough; you need to know how many units went to consumers in each state with an active EPR program. This is where most producers find the compliance burden heavier than expected, especially companies selling through multiple retail channels or online marketplaces where the final destination is not always obvious at the point of sale.
Once you have material weights and jurisdiction-level unit counts, multiply each material weight by the applicable rate from your PRO’s published fee schedule, then apply any eco-modulated adjustments for recyclability or recycled content. PROs publish updated rate schedules annually, and several states expect fee schedules for the 2026 cycle to be available by October 2026. Keep packaging specifications current, because even minor changes in material composition, label adhesives, or colorants can shift your fee category. Third-party verification of recycled content claims is not universally mandatory, but it provides auditable evidence that can support fee reduction applications and protect against penalties if your data is ever challenged.