EPR fees: designing packaging for lower costs

Lighter packaging and improved recyclability can help businesses reduce EPR fees, but savings depend on local regulations, accurate data and reliable product performance.

Extended producer responsibility (EPR) is bringing packaging waste-management costs into design, procurement and product development decisions. Depending on the scheme, fees can reflect packaging weight, material type, recyclability and other environmental criteria.

For brand owners, retailers, importers and packaging manufacturers, this creates a financial incentive to review packaging specifications. Removing unnecessary material, simplifying components and improving compatibility with recycling systems can help reduce costs.

The benefits depend on the market and the packaging format. A design that attracts a lower fee in one jurisdiction may receive different treatment elsewhere. Any reduction in EPR charges must also be weighed against material costs, manufacturing efficiency and product protection.

Understand the scheme before changing the pack

EPR schemes vary in scope, producer definitions, reporting requirements and charging methods. Businesses must understand the rules that apply to each market before deciding which packaging changes are likely to deliver savings.

Some schemes calculate fees mainly according to packaging weight and material type. Others adjust charges according to recyclability or additional environmental criteria. This approach, known as eco-modulation or fee modulation, is intended to encourage packaging designs with better environmental performance.

The UK provides a practical example. PackUK’s packaging EPR scheme introduced recyclability-based fee modulation for the 2026–27 financial year, using data on packaging supplied in 2025. Its initial modulation policy covers the period through 2028–29.

The distinction between the reporting period and the year in which fees are charged is important. A packaging redesign may not affect a company’s liability immediately.

Businesses should establish which entity is responsible, what packaging falls within scope, which data determine the charge and when changes to a specification will affect the calculation.

Reduce weight while maintaining protection

Where EPR fees are calculated by weight, lightweighting can reduce chargeable tonnage and material purchasing costs.

Opportunities include thinner container walls, lighter closures, revised dimensions and more efficient structural designs. Each change must reflect the product’s requirements and the demands of storage, handling and distribution.

A lighter container must still resist leakage, withstand handling and run reliably on filling equipment. A lower-weight carton needs sufficient stacking strength to protect its contents throughout storage and transport.

Seals and barrier layers require the same care. Reducing material without adequate testing can increase spoilage, breakage, rejected products and returns.

Packaging teams should measure material use per acceptable delivered unit, rather than assess the empty pack alone. Savings may be offset by additional cushioning, replacement shipments or product losses elsewhere in the supply chain.

The objective is to use the minimum material necessary to protect the product and maintain operational performance.

Assess the complete pack for recycling

The main packaging material does not, by itself, determine how easily a pack can be recycled.

Labels, adhesives, inks, coatings, closures and barrier layers can affect identification, sorting, processing and the quality of recovered materials. A design review should consider:

• Material combinations: whether components can be separated or processed together.
• Labels and adhesives: whether they interfere with sorting, washing or recovery.
• Colours and surface features: whether they are compatible with the detection systems used by relevant sorting facilities.
• Closures and accessories: how caps, pumps, sleeves and other components affect recyclability.
• Printing and barriers: whether inks, coatings and functional layers affect recycling processes or the quality of recovered material.

For flexible packaging, a suitable mono-material structure may replace layers that are difficult to recycle together. The redesigned pack must still provide the required barrier, sealing and mechanical properties.

Paper-based packaging also requires assessment as a complete structure. Coatings, liners and other components can affect compatibility with recycling processes.

In the UK, the applicable Recyclability Assessment Methodology (RAM) assigns red, amber or green ratings to packaging within the scheme’s scope. These ratings affect household packaging waste disposal fees. Producers must use the methodology applicable to the relevant reporting year.

Expected fee reductions should therefore be supported by the appropriate assessment, rather than inferred from a general claim that a material is recyclable.

Compare materials by total cost per pack

A lower EPR fee per tonne does not necessarily mean a lower charge per package.

An alternative material may require more weight, additional components or a different fee classification. It can also change manufacturing, storage and distribution costs.

Businesses should compare the complete packaging system, including relevant secondary and transport packaging. The assessment should cover component weights, applicable fee rates, recyclability treatment, purchasing costs, equipment compatibility and product losses.

Paper, plastics, glass and metals offer different performance characteristics. Their treatment under an EPR scheme does not, on its own, establish which material has the lowest overall cost or environmental impact.

Material substitution should proceed only where evidence shows that the alternative meets the product’s requirements and delivers a measurable benefit across the relevant cost categories.

Simplify components where possible

Unnecessary packaging complexity can increase material use, complicate reporting and create barriers to effective recycling.

Businesses should review decorative elements, redundant inserts, oversized labels and difficult-to-separate components. Before removing a feature, teams should establish its purpose and determine whether the same function can be achieved through a simpler design.

A smaller label or alternative adhesive may improve recycling compatibility in one application. Another format may benefit from a different closure or sleeve arrangement. The outcome depends on the packaging design and the relevant assessment criteria.

Simplification can also reduce assembly steps and the number of specifications held in stock. Standardising formats across product ranges may improve purchasing and production efficiency, provided the common design meets each product’s requirements.

Removing a component does not automatically improve the fee category. Businesses should recalculate the revised pack’s weight and classification, then verify any expected improvement through the applicable assessment.

Assess reuse across the full operating model

Reusable packaging may reduce demand for replacement packs, but its treatment under EPR must be checked against the relevant scheme rules.

Businesses should not assume that a reusable container automatically qualifies for an exemption or lower fee. Reporting requirements and charging arrangements vary between jurisdictions.

The wider economics depend on the number of successful uses, return rates, cleaning, transport, storage, breakage and losses. A durable pack discarded after only a few journeys may not deliver the expected savings.

Systems involving predictable circulation between known locations, such as reusable transport packaging, can provide a useful starting point. Consumer return and refill systems require practical collection arrangements and evidence that participation can be sustained.

Businesses should compare the complete operating model with the existing system, taking account of EPR charges, operational costs and environmental impacts.

Use reliable data to identify savings

Accurate packaging data support both regulatory compliance and EPR cost management.

Each approved specification should be linked to component materials, weights, quantities supplied, destination markets and applicable fee categories. Recyclability assessments and supporting evidence should be retained alongside these records.

Procurement, packaging development, finance and compliance teams need consistent information. Supplier changes, revised component weights and material substitutions should trigger updates to specifications and reporting records.

Under the UK scheme, packaging data contribute to disposal-fee calculations, while recyclability assessments influence fee modulation. Inaccurate records can therefore undermine both compliance and cost forecasts.

Once reliable data are available, portfolio analysis can identify promising redesign opportunities. High-volume formats, heavier packs and designs facing less favourable fee treatment are useful candidates for investigation.

Prioritisation should also reflect redesign costs and technical feasibility. A small reduction across millions of units may deliver greater savings than an extensive redesign of a low-volume product.

Calculate the net saving

Businesses should estimate current and proposed EPR liability using consistent assumptions for markets, packaging volumes and reporting periods.

For weight-based charges, the calculation generally starts with the chargeable weight in each category multiplied by the applicable rate, subject to the scheme’s rules and adjustments. Where fees are modulated, the calculation must also reflect the relevant rating and fee methodology.

Annual EPR fee saving = current annual EPR liability − projected annual EPR liability after redesign.

This establishes the potential fee benefit, not the complete business case.

The analysis should include material-cost changes, tooling, qualification testing, artwork revisions, supplier approvals, equipment adjustments and production trials. It should also account for any effects on production speed, waste, product damage and returns.

Where future rates remain unconfirmed, businesses should model several scenarios. They should not treat indicative fees as final or assume a favourable recyclability rating before the applicable assessment supports it.

This approach helps distinguish a reduction in one charge from a redesign that delivers a credible net commercial benefit.

Build EPR review into packaging development

Assessing EPR requirements early in product development is generally easier than changing specifications after tooling, artwork and supply agreements have been established.

Design teams should involve procurement, operations, compliance, finance and sustainability colleagues from the outset. Suppliers can propose alternative materials and structures, while manufacturing teams assess whether the changes will work reliably on existing equipment.

Before approving a redesign, businesses should establish the intended markets, applicable fee assumptions, assessment requirements and tests needed to validate the new format.

The review should continue after launch. Fee schedules, assessment methods, supplier specifications and recycling infrastructure can change, altering the financial case for an existing design.

For international portfolios, a central packaging database can support oversight, provided it retains market-specific classifications and calculations. Common formats may simplify procurement and production, but differences in local rules can justify separate designs.

Make lower EPR fees part of a wider strategy

EPR fee reduction is most effective when integrated into a broader packaging improvement programme. Focusing solely on the lowest fee could encourage substitutions that increase resource use, compromise product protection or create new recycling problems.

Businesses should balance material efficiency, recyclability, product protection, manufacturing performance and regulatory compliance. Useful performance indicators include packaging weight per unit, EPR charges, material costs, recyclability ratings and product damage rates.

Regular reviews of local requirements are essential for companies operating across several markets. Changes to fee structures or assessment methods may alter the financial case for an existing design, while improvements in recycling processes may create new opportunities.

Lower EPR fees are not achieved through material substitution alone. They depend on understanding the applicable rules, maintaining accurate packaging data and designing formats that perform efficiently throughout their life cycle.

By connecting fee modelling with packaging design, procurement and operational testing, businesses can identify credible savings without compromising product protection or transferring costs elsewhere in the supply chain.