Packaging EPR data submission window has been open for around 1 month now. However, pressure will be mounting as schemes apply their earlier deadlines with increasing reminders over the coming weeks. This isn’t new, it’s a re-run of reporting processes, some updates to recyclability assessments, to generate a report generally looks like what you did back in March/April.
However, the consequences in terms of cost are further elevated with another year of recyclability assessment methodology RAM bonuses-penalties. That means upto 20% extra costs for Red classified packaging. And as I’m seeing increasingly often, any packaging that doesn’t have the full assessment to correctly complete the RAM, gets that same penalty, even if it’s something benign like a traditional cardboard.
In light of the latest official notices regarding resubmissions of 2025 sales volumes, it’s good to scratch beneath the surface to better understand what these costs and the timing actually mean in practise i.e. when you need to pay.
Last year we were expecting pEPR invoicing to be landing around summer 2026 based on what was reported for 2025. Time has crept on, we’ve had various revisions of data and overall system costs have been realised and re-distributed. From a high level this is all as planned. Everyone gets a share of the system cost. But in practice, the timeline simply hasn’t been able to keep up with the data changes to deliver a cost to producers in good time.
It’s now evident the calculation of those final household collection costs and more importantly, how that fixed cost is shared across all registered UK producers, will not be available until at least the October/November window in 2026.
What this means is the household packaged product you sold in 2025, will not be paid for until about Christmas 2026. If we think about budgeting the true cost-of-sale for those goods and how they were priced, how does that stack up against budgets, profit-losses and overall viability of product? That’s when the real Mystic Meg moment lands – predicting, modelling and formulating annual compliance costs for pEPR becomes a real fine art.
And this isn’t a one off. It will be like this for the foreseeable. Sell something in January, you will pay for that a good 18 -22 months later. Buy now, pay later – but is that a positive or not? This should highlight to any business leaders not only the financial implications of pEPR on the business – which is typical 4-8x more than PRN system of old – but how that cost and cashflow actually lands and setting your business up to succeed rather than fail on a price point.
So, what can you do?
Push that crystal ball to one side. Hold on hiring a Mystic Meg. pEPR fees should begin to settle over the coming years as the system beds down. I’m not saying its going to be plain sailing, but this is just year 2 remember. Here are my top 5 tips to get thorugh this transition period:
- Baseline where you are now (tonnes, costs, data completeness)
- Tighten up on interpretations and aspects of scope – get these solid and verified,
- Focus on costs and volumes of leading sales units – what are these products? Will they be around in 2 yrs? Which do you have greater control over?
- Carry out a (recurring) gap analysis on data points like RAM and unit weights – this gives you a hot spot for supporting product and packaging changes,
- Track the policy narrative – join the monthly Circular Economy Joint Stakeholder Forums as a minimum, and listen between the lines on system operations and market share updates, then use these collective results alongside strategic sales targets to estimate and refine future years compliance costs.
Want to learn more, or need support implementing these top tips? I support clients with international product, packaging and waste regulation. From the immediate here and now of scoping and registering, through to longer term circularity strategy and compliance reporting management.
Contact me to book a call so I can share more about how I can help fix your product packaging and waste compliance needs.