Packaging EPR is becoming a supply chain cost, not just a compliance obligation.
As US states introduce different rules and UK fees increasingly reflect packaging recyclability, fresh produce businesses must establish who pays, whether costs reach growers and which packaging changes deliver genuine savings.
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For growers, packers, shippers and retailers, the distinction between legal responsibility and commercial cost is critical. The business required to report packaging and pay fees may recover those costs through customer prices or supplier agreements.
Whether growers ultimately receive less depends on how those agreements allocate expenses.
US state programmes and the UK’s recyclability-linked fees present different challenges, but both make accurate packaging data and clear commercial terms more important.
Businesses need to understand their obligations in each destination market and assess packaging choices against the full cost of delivering saleable produce.
US programmes follow different timetables
Extended producer responsibility (EPR) shifts responsibility for managing packaging waste towards businesses that place packaging on the market.
US state programmes differ in their definitions of a producer, covered materials, exemptions and implementation schedules.
Oregon shows how these requirements translate into financial obligations. Under its Recycling Modernization Act, obligated producers of covered packaging, paper and food serviceware must register with an approved producer responsibility organisation, report supply data and pay fees.
Circular Action Alliance (CAA), the state’s approved organisation, was authorised to begin charging member producers from 1 July 2025.
Reported material volumes help determine fee allocations. Businesses must identify covered products, establish whether they are the obligated producer and apply the appropriate reporting methodology. Oregon’s official producer guidance explains the requirements and exemptions.
Washington follows a different timetable. Its Recycling Reform Act establishes a producer-funded programme for residential packaging and paper products.
Assessments, rulemaking and programme development precede the planned expansion of recycling services in 2030. Reimbursements to eligible recycling service providers are scheduled to increase in stages, reaching at least 50% of net costs by February 2030, 75% by February 2031 and 90% by February 2032.
The Washington Department of Ecology provides programme information and implementation updates.
For shippers supplying several states, these differences require careful planning. A law’s enactment date does not establish when registration, reporting, payments or service changes begin. Businesses need to track each milestone in every applicable programme.
Legal responsibility also cannot be inferred from who purchases a punnet or packs a carton. Brand ownership, importing arrangements and statutory definitions may determine the obligated producer.
Commercial agreements can distribute costs between partners, but cannot override legal obligations.
How costs could reach growers
A packing business may initially record an EPR fee as its own expense. The eventual impact depends on whether it absorbs that cost, recovers it from customers or passes it to growers through agreed charges.
Consider a grower whose payment is calculated after packing and marketing expenses are deducted from sales proceeds.
An additional recoverable compliance charge could reduce that grower’s net return. Under a fixed-price purchasing agreement, the immediate cost may instead remain with the buyer or packer.
These examples illustrate how costs could move through the supply chain. They do not establish that growers will automatically face new deductions.
Calculating the cost per saleable pack or case provides a useful starting point. Combining packaging weights, destination volumes and applicable fees allows businesses to estimate their exposure and assess how contracts allocate it.
That calculation should distinguish statutory EPR fees from compliance-service charges, packaging-price changes and other operating expenses. A transparent breakdown helps growers and customers assess proposed surcharges and gives procurement teams a clearer basis for comparing alternatives.
UK fees bring recyclability into the calculation
The UK’s packaging EPR scheme provides a different model, linking household packaging waste-disposal fees to recyclability.
Large obligated producers may face both disposal fees and separate recycling-evidence obligations. The latter are met through packaging recycling notes (PRNs) or packaging export recycling notes (PERNs). Businesses need to budget for these requirements separately.
Packaging classification matters, too. A transport carton or pallet should not automatically receive the same disposal-fee treatment as packaging that becomes household waste. Each format must be assessed against the relevant rules.
PackUK’s published modulation policy applies the first recyclability-adjusted disposal-fee calculations in the 2026–27 financial year, using packaging supplied in 2025. Under the Recyclability Assessment Methodology (RAM), packaging receives a red, amber or green rating.
Red-rated packaging attracts a multiplier of 1.2 on the relevant household packaging waste-disposal fee in 2026–27. The published policy increases this to 1.6 in 2027–28 and 2.0 in 2028–29.
Amber-rated packaging receives no modulation adjustment. Additional revenue from red-rated packaging funds discounts for green-rated material. Modulation therefore changes how household packaging waste-disposal costs are allocated, rather than increasing the total amount of these fees collected.
Crucially, the multiplier applies to the disposal-fee component, not the whole compliance bill. Buyers comparing packaging options need the applicable rating, material weight and fee category to calculate potential savings.
PackUK administers the scheme, while environmental regulators oversee compliance. Providers such as Ecosurety offer packaging compliance and data support. Businesses using these services still need to understand their obligations and supply accurate information.
Packaging savings depend on product protection
For fresh produce, lower packaging fees are only part of the calculation.
Berry punnets, including hinged clamshell formats, must protect vulnerable fruit during stacking and handling. Films, trays and corrugated cartons serve different purposes, and changing one component can affect packing operations, transport and retail presentation.
A lighter pack could reduce material use and the weight attracting relevant fees. A more recyclable design could improve its UK rating. Either change must preserve product quality throughout distribution.
The commercial assessment should include packaging materials, EPR fees, packing-line efficiency, transport and losses from damaged or unsaleable produce.
Savings on packaging can disappear if a revised specification increases rejected deliveries or spoilage.
International suppliers face another variable: destination-market requirements. A favourable UK recyclability rating does not establish equivalent treatment under a US state programme. Local collection and processing infrastructure also affects whether a packaging format can be recycled in practice.
The objective is to assess the full cost and performance of a packaging format, rather than optimise one fee or material characteristic in isolation.
Connect packaging data with commercial agreements
The immediate priority is to bring packaging specifications, legal obligations and contracts into the same decision-making process.
For each relevant format, businesses need reliable records of material composition, weight, destination and the organisation responsible for compliance.
Supplier information should be checked against actual packaging use, with documented methods for calculating reported quantities.
Contracts should explain how identifiable compliance costs are treated, whether they can be passed to customers or growers, and when regulatory changes trigger a review of prices or charges.
Clear calculations also help commercial partners identify overlapping surcharges.
Procurement teams can then compare packaging options using consistent assumptions, supported by trials of packing-line performance, transport conditions and product protection.
In the UK, the scheduled increase in the red-rated disposal-fee multiplier to 1.6 in 2027–28 gives businesses a specific reason to review designs and budgets. In the US, reporting and payment milestones require monitoring state by state.
For growers and their supply-chain partners, the test is whether verified costs are allocated transparently—and whether packaging changes reduce the total cost of delivering saleable produce to market.
