EPR Help for SMEs: 5 Practical Steps to Stay Compliant & Avoid 2026 Fee Increases
As a UK SME handling packaging, you’re likely feeling the pressure - data collection, new reporting rules, and those looming 2026 modulated fees. With PackUK’s confirmed June 2025 household packaging base rates (£423/t for plastic, £192/t for glass) and RAM-based modulation due from 2026 onward (1.2x red premiums applied to 2025 RAM data), non-compliance could add 20–50% to your costs.
But here’s the good news: staying compliant isn’t about hiring a large scheme or navigating endless guidance. It’s about taking a few simple, repeatable steps to remain audit-ready and avoid penalties.
Not sure if you’re in scope or what to do next?
Any business placing packaging or packaged goods on the UK market may be an obligated producer under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332).
Large producers:
Turnover ≥£2m and >50 tonnes packaging/year
H1 report (Jan–Jun) due 1 October
H2 report (Jul–Dec) due 1 April
Most SMEs in food, drink, beauty, or e-commerce qualify automatically. Use the GOV.UK scope checker if unsure.
Small producers:
Turnover ≥£1–2m and 25–50 tonnes packaging/year
Submit annually (report-only; no fees unless large thresholds are met)
If you rely on suppliers, ensure weight data is complete and accurate - SMEs often under-report where packaging is shared or third-party packed.
You’ll need accurate supplier data for:
Packaging weights (grams → kilograms → tonnes)
Materials (plastic, paper/card, glass, aluminium, steel, wood)
Format (bottles, tubs, jars, pouches, films, trays)
Country of supply
RAM ratings (Green / Amber / Red)
Tip: Keep a single spreadsheet updated quarterly for all materials. This reduces the risk of missing information during reporting.
Key dates:
1 October 2025 - H1 deadline for large producers (Jan–Jun 2025 data)
1 April 2026 - Full-year 2025 data for small producers + H2 data for large producers
1 April annually - Registration deadline
Modulated fees apply from 2026, based on 2025 RAM data (subject to DEFRA’s final methodology)
Evidence retention: 7 years (Regulation 34)
Missing EPR deadlines is the fastest way SMEs trigger enforcement action.
Penalties:
Fixed Monetary Penalties (FMPs) up to £1,500 for late/missing submissions
Additional data review requirements where inconsistencies are found
Risk of higher civil penalties under the Environment Act 2021 for incorrect or misleading data
Potential recovery of underpaid fees where reporting errors affect the 2026 modulated fee calculation
Add reminders now - don’t rely on supplier timelines.
Environment Agency Enforcement and Sanctions Policy
Environment Act 2021, Schedule 7
Under Regulation 34, all producers must retain evidence for 7 years, including:
Supplier weight files
Material breakdowns
RAM alignment evidence
Data mapping decisions
Volumes, URLs, invoices
Submission files (RPD Portal)
Evidence must be provided within 14 days if requested by the regulator.
Base rates for 2025 (PackUK household packaging):
Plastic: £423/t
Glass: £192/t
RAM multipliers applied from 2026 onward:
Green: 0.9x
Amber: 1.0x
Red: 1.2x (rising to 2.0x by 2028)
