Table of Contents
- Two Separate Obligations
- Side-by-Side Comparison
- Who Pays What
- Interaction Between the Two
- How to Manage Both
- Key Takeaways
Key Takeaways
- EPR and the Plastic Packaging Tax are completely separate obligations — complying with one does not exempt you from the other.
- EPR applies to ALL packaging materials (plastic, paper, glass, metal, etc.); the Plastic Packaging Tax applies ONLY to plastic packaging.
- The Plastic Packaging Tax is triggered by less than 30% recycled content — achieve 30%+ recycled content and the tax drops to zero.
- EPR fees are based on weight and recyclability; the Plastic Packaging Tax is based purely on weight and recycled content.
- Combined plastic packaging costs can exceed £670/tonne for non-recyclable virgin plastic.
Two Separate Obligations
UK businesses dealing with plastic packaging face two distinct regulatory charges:
- Extended Producer Responsibility (EPR) — administered by PackUK, covering all packaging materials
- Plastic Packaging Tax (PPT) — administered by HMRC, covering only plastic packaging
These are separate charges with different triggers, different administrators, and different exemption criteria. A business can owe one, both, or neither depending on its activities.
For EPR details, see what packaging EPR is. For the existing comparison with more context, see our detailed packaging EPR vs plastic packaging tax guide.
Side-by-Side Comparison
| Feature | EPR | Plastic Packaging Tax |
|---|---|---|
| Administered by | PackUK / Environment Agency | HMRC |
| Applies to | All packaging materials | Plastic packaging only |
| Trigger | £1M+ turnover AND 25+ tonnes packaging | Manufacture or import 10+ tonnes plastic packaging |
| Rate | £192-£461/tonne (varies by material) | £210.82/tonne (flat rate) |
| Exemption | Below turnover/tonnage thresholds | 30%+ recycled content |
| Payment | To PackUK | To HMRC |
| Reporting | DEFRA RPD portal | HMRC tax return |
| Frequency | Annual or six-monthly | Quarterly |
| Purpose | Fund packaging waste management | Incentivise recycled content |
Who Pays What
Scenario 1: Large Manufacturer Using Virgin Plastic
A manufacturer producing 100 tonnes of virgin plastic packaging:
- EPR fee: 100t x £360/t = £36,000
- PPT: 100t x £210.82/t = £21,082
- Total: £57,082
Scenario 2: Same Manufacturer with 30%+ Recycled Content
Using 30% recycled plastic:
- EPR fee: 100t x £360/t = £36,000 (unchanged)
- PPT: £0 (exempt — 30%+ recycled content)
- Total: £36,000 (saving £21,082)
Scenario 3: Business Using Only Paper/Card Packaging
100 tonnes of corrugated cardboard:
- EPR fee: 100t x £215/t = £21,500
- PPT: £0 (PPT applies only to plastic)
- Total: £21,500
Scenario 4: Small Business Below Both Thresholds
Turnover £500K, 10 tonnes of packaging:
- EPR fee: £0 (below £1M turnover threshold)
- PPT: £0 (below 10-tonne threshold)
- Total: £0
Interaction Between the Two
They Are Cumulative
If you owe both EPR fees and PPT, you pay both in full. There is no offset or deduction between the two charges.
Different Calculation Bases
- EPR uses all packaging placed on the UK market (including paper, glass, metal)
- PPT uses only plastic packaging manufactured or imported (with <30% recycled content)
Different Thresholds
You may be obligated under one but not the other:
| Situation | EPR? | PPT? |
|---|---|---|
| £2M turnover, 60t total packaging (40t plastic, 20t card) | Yes | Yes (if <30% recycled) |
| £500K turnover, 15t plastic packaging | No | Yes |
| £3M turnover, 30t card packaging only | Yes | No (no plastic) |
| £1.5M turnover, 30t packaging (all 30%+ recycled plastic) | Yes | No (exempt from PPT) |
How to Manage Both
Step 1: Determine Your Obligations
Calculate your turnover, total packaging tonnage, and plastic packaging tonnage separately to determine which regimes apply.
Step 2: Track Recycled Content
For PPT, track the recycled content percentage of each plastic packaging component. Achieving 30% exempts you from the tax entirely.
Step 3: Separate Reporting
Maintain records that support both reporting requirements:
- EPR: Material type, weight, packaging category, nation data
- PPT: Plastic type, weight, recycled content percentage, origin (manufactured/imported)
Step 4: Optimise for Both
Actions that reduce costs under both regimes:
- Lightweighting — reduces both EPR tonnage and PPT tonnage
- Increasing recycled content — reduces PPT (and may reduce future EPR fees)
- Switching from plastic to paper — eliminates PPT and may reduce EPR fees
Step 5: Budget for Both
When forecasting packaging costs, include both EPR fees and PPT in your calculations.
The Business Case for Recycled Content
The PPT creates a strong financial incentive to use recycled plastic:
| Plastic Packaging Type | EPR Fee | PPT | Total |
|---|---|---|---|
| Virgin, non-recyclable | £440/t | £210.82/t | £650.82/t |
| Virgin, recyclable | £340/t | £210.82/t | £550.82/t |
| 30%+ recycled, recyclable | £340/t | £0 | £340/t |
The total saving from using recycled, recyclable plastic vs virgin non-recyclable is £310.82/tonne.
For more on recycled content, see our recycled content packaging guide.
Getting Started
- Calculate your obligations under both EPR and PPT
- Audit your recycled content — are you above or below 30%?
- Estimate combined costs using the EPR fee calculator
- Develop a plan to reduce costs under both regimes
- Set up dual tracking in your data collection system
Visit our pricing page for compliance tools, and check the glossary for definitions.