EPR Packaging in the UK: What Ecommerce Brands Report, Pay and Ask Their 3PL

UK packaging EPR (extended producer responsibility) makes the businesses that supply packaging report it and, if they are large producers, pay for its disposal. You are in scope if you are established in the UK, your annual turnover is £1 million or more and you supplied or imported more than 25 tonnes of packaging in the previous calendar year. Large producers (£2 million or more and over 50 tonnes) report twice a year and pay waste management fees set by PackUK. Small producers report once a year and pay none.

For a brand that uses a 3PL, the hard part is the data. Every box, mailer and air pillow has to be weighed and counted by material.

The pain points

• A fee notice arrived and nobody had put it in the budget.

• We have no idea what our packaging weighs, by material, per order.

• The 3PL picks the box size and the void fill. Whose packaging is that?

• We are close to 50 tonnes and cannot tell if we become a large producer next year.

Work out whether you are large or small

Tonnage is the packaging you supplied or imported in the previous calendar year, so your 2025 packaging set your position for 2026. Turnover comes from the last accounts available before 7 April of the current year. Groups add up turnover and tonnage across every member that supplies or imports packaging.

• Out of scope: turnover under £1 million, or 25 tonnes or less of packaging.

• Small producer: turnover of £1 million or more and between 25 and 50 tonnes, or turnover between £1 million and £2 million with more than 25 tonnes.

• Large producer: turnover of £2 million or more and more than 50 tonnes.

Count only the packaging you are responsible for (see the 3PL section below).

What you report and when

You report packaging weight in kilograms by material: aluminium, fibre-based composite, glass, paper or card, plastic, steel, wood and other. Large producers also split it by class (primary, secondary, shipment and tertiary), by household or non-household, and give recyclability data for household packaging. Shipment packaging is the box, mailer or bubble wrap on goods sent to consumers. Both large and small producers report nation of sale: England, Scotland, Wales or Northern Ireland.

The gov.uk deadlines for 2026 data are:

• Large producers: January to June 2026 data was due on 1 October 2026. July to December 2026 data is due on 1 April 2027. They also register and pay fees by 1 October each year.

• Small producers: all of 2026 is due on 1 April 2027, with registration by 1 April each year.

Changing data after you submit it can cost a resubmission fee of £807 if you registered directly with your regulator, or £512 through a compliance scheme.

What the 2026 to 2027 fees look like

PackUK's illustrative 2026 to 2027 fees, published in December 2025, are per tonne at the amber rate and may still change:

• Paper and board: £210

• Plastic: £455

• Glass: £205

• Aluminium: £270

• Steel: £290

• Wood: £450

• Fibre-based composite: £525

• Other: £225

2026 to 2027 is the first year the recyclability assessment (RAM) changes the fee. Each household packaging item is rated red, amber or green. Amber pays the base rate. Red pays 1.2 times the amber disposal element this year, rising to 1.6 times in 2027 to 2028 and 2 times in 2028 to 2029. Green gets a discount, shown as about 9% in the illustrative figures. Packaging with no evidence for amber or green is reported as red.

Order boxes and mailers are generally reported as household packaging, which carries the disposal fee. PackUK has said it expects to publish confirmed fees and issue notices of liability later in 2026. Producers then have 50 calendar days to pay, with instalments available. The illustrative rates are on gov.uk: year 2 illustrative waste disposal fees.

Who is the producer when your 3PL packs the order

The gov.uk guidance assigns packaging by activity:

• Brand owner: filled packaging with your brand on it is yours to report, even when you pay another business to pack, make or import it. A printed mailer or a branded box counts here.

• Packer or filler: unbranded packaging is reported by the business that packs or fills it, whether for itself or for another organisation. Plain shipping boxes, paper fill and air pillows added by your 3PL fall here.

• Importer: if you bring filled packaging into the UK, such as stock from an overseas factory, the packaging on it can count as yours.

The guidance does not name 3PLs, so agree the split in writing. Name each packaging item, say who reports it and confirm the 3PL is itself an obligated producer if it is taking the unbranded items. The gov.uk compliance checker sets out the rules.

What to ask your 3PL for

• A packaging list for every item they use on your orders: material, weight in grams, branded or unbranded, and class.

• Monthly usage counts for each item, so weight per order becomes total weight per period.

• Orders split by delivery nation for your nation of sale data.

• The supplier's recyclability rating, with evidence, for each household item.

• Notice before they change a box, mailer or fill type.

Add these to the list in our guide to questions to ask a 3PL before you sign.

Our recommendation: get the packaging data in writing this quarter

1. Take last calendar year's packaging tonnage and your latest accounts. Place yourself in the bands above.

2. Build a packaging spec sheet: every item, its material and its weight.

3. Ask your 3PL for monthly usage by item and by delivery nation.

4. Agree in writing who reports branded and unbranded items.

5. Collect RAM ratings from your packaging suppliers and look for red items you can replace before 2027.

6. Budget the fee from the illustrative rates and update it when PackUK confirms them.

Then add packaging to the other lines in what a 3PL costs in the UK, and use our pillar guide on how to choose a 3PL for the full selection.

What waiting costs

These figures are made up to show the method, using PackUK's illustrative 2026 to 2027 rates. A brand with £6 million turnover ships 300,000 orders a year. Each goes in a 180 g corrugated box with 12 g of plastic air pillows: 54 tonnes of board and 3.6 tonnes of plastic, so it is a large producer.

At amber rates the bill is about £11,340 for the board and £1,638 for the plastic. If the pillows are rated red, the plastic line rises to about £1,962, and the red multiplier grows in each of the next two years. Cutting 20 g from each box removes 6 tonnes of board, around £1,260 a year at the amber rate. Each of those choices needs per item data from the warehouse.

July to December 2026 data is due on 1 April 2027, and the packaging you ship this year decides your status next year.

People Also Ask

Do small producers pay EPR fees?

Small producers pay no waste management fees. They register each year, pay a registration fee to their regulator and report their packaging data once a year. Small producers' 2026 data is due by 1 April 2027.

Is my 3PL responsible for EPR on my packaging?

Packaging with your brand on it is yours to report, even when a 3PL packs it. The gov.uk guidance says unbranded packaging is reported by the business that packs or fills it, which can be your 3PL if it is an obligated producer. Agree the split item by item in writing.

When are EPR fees for 2026 to 2027 due?

PackUK has said it expects to confirm the 2026 to 2027 fees and issue notices of liability later in 2026. Large producers then have 50 calendar days to pay and can pay in instalments. Check PackUK's latest update for exact dates.

Finding the right 3PL partner

Logan, FulfilQ's advisor on the website, matches brands to verified providers by order volume, product type and region. Tell Logan what you ship and where it goes, and you get a shortlist you can ask about packaging data by item, material and weight per order. Start at fulfilq.com and Ask Logan, or Submit an RFP and verified providers come back to you. You can also browse the full provider directory.