EPR Packaging Labelling: How RAM Will Lower (or Increase) Your 2027 Modulated Fees
The UK’s Extended Producer Responsibility (EPR) framework has been a major focus for packaging compliance, with many businesses anticipating mandatory “Recycle / Do Not Recycle” labels on all household packaging by 2026–2027.
As of 2025, the landscape has shifted. DEFRA has removed mandatory packaging labelling requirements from the drafted framework to avoid implementation delays, reduce short-term costs, and prevent friction with upcoming EU reforms.
Here’s a clear breakdown of what this means for your business and how to stay compliant.
Labelling requirements were announced as removed in DEFRA’s September 2024 EPR policy update.
DEFRA will revisit the issue once there is more clarity around the EU’s Packaging and Packaging Waste Regulation (PPWR), which entered into force in February 2025, with major provisions applying from August 2026 onward.
The regulatory focus now is on data accuracy, recyclability assessments, and fee forecasting - not packaging artwork.
Large Producers:
Must collect packaging data continuously (quarterly basis) and submit twice per year:
H1 (Jan–Jun) → submission due 1 October
H2 (Jul–Dec) → submission due 1 April
(This reflects quarterly data collection and bi-annual submission windows.)
Small Producers:
Must submit annual data by 1 April each year.
Producers Fees
Base fees apply for 2025, based on 2024 data (first invoiced October 2025 via PackUK).
Modulated fees apply from 2026 onward, based on 2025 recyclability assessments using DEFRA’s RAM.
Evidence Retention
Businesses must keep:
Supplier declarations
Material/component weight records
Data submission logs
RAM recyclability assessments
(All retained for at least 7 years, per SI 2024/1332)
OPRL (On-Pack Recycling Label) - the recommended and most recognised voluntary scheme.
Retailer or brand icons, provided they do not mislead consumers or contradict UK recycling guidance.
DEFRA supports voluntary consistency but applies no legal obligation to adopt any label.
Strengthen data collection: Confirm supplier-provided weights, materials, and specs are complete and traceable
Prepare for modulated fees: From 2026, non-recyclable packaging will incur higher charges based on RAM assessments
Budget accurately: Include base fees (2025) and modulated fees (2026 onward) in financial plans - with invoices typically issued in October
Maintain robust evidence files: Retain all supporting documentation for EA audits
Apply recyclability criteria: Use DEFRA’s RAM guidance to classify packaging ahead of modulated-fee calculations
Stay informed: Subscribe to DEFRA alerts to monitor upcoming changes, especially around the future of labelling
Interpret and apply the latest EPR guidance
Build supplier data workflows and templates
Prepare and structure data for accurate fee forecasting under 2025–26 rules
Maintain year-round audit readiness and evidence tracking
