How to calculate your first pEPR invoice

what is the Notice of Liability (NoL) for packaging EPR?

If you work in finance or accounts you will soon see invoices that look unfamiliar and expensive. These are the first packaging Extended Producer Responsibility or pEPR invoices under the new UK packaging Regulations. They cover packaging you supplied during 2024. This short post explains what the invoice pays for, how the costs have been calculated, and how you can check it quickly and confidently to avoid late payment penalties.

What is the EPR invoice for

The invoice is the producer fee for managing household packaging waste collections. The money funds local authority collection, sorting and recycling services. It also covers programme administration and operational costs for PackUK as scheme administrator. The amount reflects the volume (in tonnes) and type of packaging your business reported as placed on the market in 2024 and the packaging waste management costs per material.

How the fee is calculated in plain terms

1. Tonnage. The regulator uses your 2024 reported weights per material type. More tonnes means higher fees.
2. Base fees. These are calculated by dividing packaging waste management costs (for household packaging waste) and other relevant costs by the total amount of household packaging placed on the market. The result is a fee rate which is expressed in £ per tonne of packaging placed on the market.
3. Scheme administration costs, public information disposal costs, and impairment provision for bad debt, are split out on the invoice and cover your share of the total operational and system costs.
4. Payment terms are set as 50 days regardless of your own standard contractual terms. Otherwise, the payment can be split into 4 instalments upon request, with payments made by Direct Debit.
5. The payment is classified as a statutory or regulatory debt, not a traditional supplier invoice.
6. Variable monetary penalties are applicable for late payment; 20% of the fees, or 5% of your turnover.

Quick checklist for verifying the invoice

The Notice of Liability (invoice) will be accessible through the Report Packaging Data (RPD) system in October 2025.

Once issued, PackUK will notify Primary Contacts and Approved Users and advise them how to access their invoice. Approved users are those who set up the RPD account and hold legal responsibility for it. Only RPD users can administer the account, download the invoice.

Use this as your first internal audit when the invoice arrives.

1. Check the invoice breakdown by material. You should see tonnes per material.
2. Check the invoice unit cost per material (as published).
3. Reconcile invoice totals to the declaration authorised by your Approved User (likely to be a Director of your company).
4. Check with the individual who calculated these totals. Match all tonnes declared to the tonnes calculated in the backing data.
5. Briefly check how the backing data totals were calculated. How is household versus non household split? What sales are included or excluded? Are these tonnes from imported, own brand, and unbranded new packaging, that you have added? Confirm the basis for any calculations applied.
6. For any grey areas consult with your scheme (if you have one), resident compliance expert or contact us for an informed opinion. Alternatively, check online guidance.
7. If something does not match, or you want to change the payment plan, contact the EPR helpdesk telephone line on 0300 060 0002.

Why RAM matters now and for 2026 and beyond

RAM stands for Recyclability Assessment Methodology. It is a system that will be used to judge how recyclable the packaging declared in your pEPR return is. RAM scores will influence fee modulation from 2026. That means packaging that scores poorly will carry higher fees (a red grading receives a +20% penalty). Packaging that scores well will pay less (a green grading).

You should already be preparing recyclability assessments based on your 2025 sales, and can now hopefully see the importance and consequence of these data outputs. Good RAM evidence can reduce your fee exposure next year. Poor or missing evidence will likely increase these already high invoice costs.

Practical actions finance teams can support now

1. Reconcile packaging tonnage. Work with operations to produce a single verified dataset. If you need help with a managed EPR reporting software tool, contact us to discuss how we help.
2. Gather supporting documents for RAM now. Put them in one secure folder for quick retrieval.
3. Prioritise RAM assessments for high volume SKUs. Focus on items that drive the invoice total.
4. Ask procurement to confirm material composition and characteristics for each SKU. Get supplier declarations in writing.
5. Model fee sensitivity. Run simple scenarios to show leaders the financial impact of different RAM outcomes. We can help with software tools to make this easier.
6. Consider quick redesigns or material swaps for the highest cost lines where feasible.

How circumetrics can help

As a member of the PackUK technical advisory committee (TAC) for the recyclability assessment methodology (RAM), our Director Mark Sayers works closely with clients to manage the RAM applications and reporting. There is practical RAM guidance and data reconciliation templates to help you do this manually, or software tools form our associates to digitize a compliance solution for you. We help teams validate invoices, prioritise RAM work and model likely fee impacts. We also run workshops that bring finance, procurement and packaging design teams together to learn how they impact EPR fees and how to act fast.

If you want a simple invoice validation or a one page RAM guides I can help. If you need a software solution to manage your RAM data reporting, get in touch for a demo.