Packaging EPR ‘illustrative’ fees updated
Government published updated ‘illustrative’ packaging EPR (pEPR) disposal fee rates on Monday 30th of September 2024, since updating the calculation methodology and following industry engagement.
The second iteration of ‘illustrative’ disposal fees has been published, which you can find here: Extended producer responsibility for packaging: illustrative base fees. You can read our news story on the first iteration of disposal fees.
As a reminder, pEPR disposal fees are a new financial obligation for large producers under pEPR. These fees will apply to large producers that supply household packaging and packaging that commonly ends up in public bins, as defined under pEPR, to the UK market during 2024 and will be first charged in October 2025.
This second iteration of ‘illustrative’ fee rates are not the final fee rates which producers will be charged in October 2025, they are still an estimate. Government will not be able to determine the final fee rate which will be charged, until all the 2024 placed on market packaging data has been submitted. The submission deadline for this data is the 1st of April 2025.
How are the disposal fee rates calculated?
The following formula has been used to calculate the ‘illustrative’ disposal fee rates and will be used to calculate the final disposal fee rates in 2025.
Why have Government updated the ‘illustrative’ fee rates?
In this second iteration, Government have used a consistent methodology across all material types, compared to the first iteration for which two methodologies were used due to data availability.
Government have also used more up-to-date data sources for two elements of the disposal fee formula:
1. Total weight of packaging placed on UK market data
The first iteration of ‘illustrative’ disposal fees published in August 2024 used PackFlow Refresh 2023 reports, which estimate packaging placed on the market in 2022. This was used as this dataset was the best available and most up to date indication of total weight of packaging placed on the UK market at the time. Government have updated their calculations to now use 2023 placed on market data reported by producers.
2. Costs incurred by local authorities managing waste
The first iteration of ‘illustrative’ disposal fees used local authority disposal costs estimated by WRAP local authority cost model (except for glass). Government have produced their own ‘Local Authority Packaging Cost and Performance’ model, which has been used for all materials in this second iteration of fees. The model is still undergoing finalisation but is the methodology which will be used to calculate final fees that will be invoiced in 2025.
Second iteration of ‘illustrative’ disposal fee rates
|
Material |
Lower (£ per tonne) |
Intermediate (£ per tonne) |
Higher (£ per tonne) |
Intermediate percentage change (compared to first iteration – Aug 2024) |
|
Aluminium |
320 |
405 |
605 |
-18.18% |
|
Fibre-based composite |
355 |
450 |
565 |
-14.29% |
|
Glass |
110 |
175 |
215 |
-32.69% |
|
Paper and card |
135 |
190 |
250 |
-26.92% |
|
Plastic |
360 |
425 |
520 |
-17.48% |
|
Steel |
220 |
265 |
330 |
-10.17% |
|
Wood |
145 |
240 |
340 |
-9.43% |
|
Other |
180 |
205 |
240 |
-22.64% |
What are the changes in fee rates compared to the first iteration?
The above table displays the percentage change between the intermediate fee rate of the second iteration of ‘illustrative’ fees compared to the intermediate fee rate in the first iteration. The graph below visually compares the fee ranges from the first iteration and the second iteration.
The intermediate fee rate for all materials has decreased, with glass and paper and card showing the greatest reductions. It is clear from the graph below that the ranges have tightened and become slightly more precise, only wood has expanded slightly.
Since the publication of the first iteration of ‘illustrative’ fee rates, Government have engaged with material specific organisations and stakeholders in industry, including glass, plastic and metals (steel and aluminium) stakeholders. In these engagements Government was advised by industry on how to improve the methodology used to calculate the ‘illustrative’ fee rates.
As mentioned earlier, these rates are still very much an estimate and will be refined further when Government publish the next iteration in the New Year (2025) using the more up-to-date January – June 2024 placed on market data submitted by producers and compliance schemes to Government for the 1st of October 2024. This third iteration to be published will give us a more accurate estimation of the disposal fee rates that will be charged in 2025.
Timeline for 2025 disposal fees
The first set of disposal fees that producers will be charged will be based on data reported on packaging supplied on the UK market over the 2024 calendar year.
- January 2025: The Main pEPR Regulations enter into force. Government publishes the third iteration of ‘illustrative’ disposal fees.
- 1st of April 2025: all of the 2024 placed on market data should have been submitted by producers and compliance schemes to Government.
- April – August 2025: In the months following the deadline, Government will analyse the data and calculate the final disposal fee rate that will be charged to producers, considering any missing producer’s data submissions and likely missing tonnage.
- ‘Summer 2025’ (exact date tbc): Government will notify producers of the final disposal fee rates they will be charged from October 2025.
- October 2025: Invoices will be raised to producers for 2025 disposal fees.
- November 2025: the first Direct Debit payment will not be collected until at least 45 days after the date of the invoice.
Producers will have the ability to make payments via quarterly instalments. For the first year of fees, Defra expect these instalments to be paid during:
- November 2025
- January 2026
- April 2026
- June 2026
Key takeaways
- This second iteration of ‘illustrative’ disposal fees provides us with a more accurate estimation of the disposal fees that they will be charged in October 2025 (compared to the first iteration), as more up-to-date data has been used.
- The intermediate rate has reduced across all materials.
- These updated fee rates are still ‘illustrative’ and are estimations based on the best available data.
- Government will notify producers of the final fee rate once all the 2024 placed on market data has been submitted for 1st of April 2025.
Support for producers
Beyondly are here to support our members every step of the way during the pEPR reform, so if you have any questions or would like to share your thoughts with us, please drop a line to our team on packaging@beyond.ly
We would recommend signing up to the Resources & Waste newsletter published by the Government, in which they share the latest news and engagement sessions relating to the resources and waste reforms.
Member reminder: please submit any outstanding placed on market data for 2023 or January – June 2024 to Beyondly via our Member Portal here: https://portal.beyond.ly/ The deadlines for us to submit this data to Government have now passed, so this must be actioned as soon as possible.