Extended Producer Responsibility (EPR) and the modulated fees now announced by The Department for Environment, Food and Rural Affairs (DEFRA) represent a seismic and potentially very costly shift in packaging compliance, and it’s no time for ‘heads in the sand’. For businesses in the DIY, home improvement and garden sectors, the choice is stark: adapt now and take control of your packaging costs or face steep financial penalties and equally destructive reputational risks.
At BHETA, we are committed to helping members prepare. With our partner WastePack, we offer the expertise, tools, and insight needed to reduce exposure and therefore cost. But equally we want to help companies turn compliance into competitive advantage. The mission is not just about mitigating the tax. It’s about aligning supplier businesses with the direction of travel — towards circularity, sustainability, and responsible retailing.
What’s the latest on EPR?
DEFRA has now published the packaging waste fees for the 2025 compliance year under EPR legislation. What’s coming is not simply a tax, but a powerful regulatory incentive — or deterrent — that will reshape how packaging is designed, sourced, and handled across the entire value chain. With DEFRA confirming the introduction of modulated fees and a new Recyclability Assessment Method (RAM) for 2026, the message to producers is clear: make your packaging more recyclable and include recycled content — or pay significantly more.
What this means – ‘red products’
The EPR reform shifts the full cost of managing household packaging waste away from local authorities and onto the businesses that place packaging on the UK market. For 2025, producers will pay based on the volume and type of packaging— but the step change comes in 2026, when DEFRA introduces its modulated fees. These fees will be calculated based on two key factors:
- Recyclability of the packaging (how easily and widely it can be recycled by UK local authorities)
- Recycled content (how much post-consumer recycled material is included)
The Recyclability Assessment Method (RAM) scores packaging formats against criteria such as collection rates, sortability, and reprocessing. Under this system, packaging that scores poorly — referred to as ‘red product’ — will incur a 20% uplift incompliance costs starting in 2026, with a 200% increase in base fees by 2028. The so-called ‘red product’ will likely include:
- Black plastic trays (which are difficult for optical sorters to detect)
- Multilayer films or laminates (used for bags, sachets, or pouches
- Blister packs with card and plastic (common in tools, screws, and accessories
- Packaging with mixed materials that are hard to separate
- Formats without sufficient post-consumer recycled content
What suppliers must do
The upside of all this is that businesses who get ahead can not only avoid spiralling charges but also enhance their sustainability credentials in the eyes of customers, regulators, and retailers.
- Undertake a Full Packaging Audit to determine current footprint with a view to phasing out high-risk types
- Packaging materials by SKU
- Weight and volume by format
- Levels of recycled content
- Recyclability against UK local authority capabilities
- Use the Recyclability Assessment Method (RAM)
Assess your packaging portfolio against the RAM criteria to identify red and amber-rated packaging. WastePack, a BHETA member and official Business Support Provider, can help members navigate RAM scoring. - Redesign packaging with eco-design in mind
- Shift to mono-material formats (e.g., PE-only films, carboard-only boxes)
- Replace laminated plastic or composite packs with recyclable alternatives
- Increase use of post-consumer recycled content
- Eliminate unnecessary secondary packaging
- Collaborate across the supply chain
Packaging innovation requires coordination between product teams, packagers, marketing, and logistics. Suppliers should work with specialists to co-develop compliant designs. Retailers should engage private label and third-party brands early to align packaging formats with EPR best practice. BHETA can facilitate such collaborations. - Review on-pack labelling and messaging
Sustainable packaging is not just about compliance — it’s a branding opportunity. Let customers know how your packaging is recyclable or made from recycled materials. Clear, credible on-pack communication can build trust and influence purchasing decisions. Ensure such green claims are verifiable.
How BHETA can help
The implications of EPR and RAM are a huge ask for supplier businesses, but an essential one for the future of the industry. With BHETA’s help however the transition is not just about mitigating penalties, but in using sustainable packaging to enhance brand reputation and delight increasingly eco-conscious customers.
Packaging is a rapidly evolving policy area, and businesses need to stay informed. BHETA, in partnership with WastePack, runs regular EPR Advisory Webinars for members. To access our EPR compliance support, explore the upcoming webinars or contact us at info@bheta.co.uk.
