Table of Contents
- What Is Multi-Material Packaging?
- Separable vs Non-Separable Components
- How to Classify Multi-Material Packaging
- EPR Fee Implications
- Common Multi-Material Examples
- Reporting Multi-Material Packaging
- Reducing Multi-Material EPR Costs
- Key Takeaways
Key Takeaways
- Multi-material packaging falls into two categories: separable components (report each material separately) and non-separable composites (report as composite at the highest fee rate).
- Non-separable composites attract the highest EPR fees — up to £461/tonne for fibre-based composites.
- If components can be easily separated by the consumer, they should be classified and reported as individual materials.
- Switching from non-separable composites to separable components can reduce your EPR fees significantly.
- The “predominant material by weight” rule applies to non-separable items — classify based on the heaviest material.
What Is Multi-Material Packaging?
Multi-material packaging contains two or more materials in a single packaging item. This is extremely common — a plastic bottle with a paper label, a cardboard box with a plastic window, or a food pouch with multiple polymer layers are all multi-material.
Under EPR, how you report multi-material packaging depends on whether the materials can be easily separated by the consumer or are permanently bonded together.
For EPR background, see what packaging EPR is.
Separable vs Non-Separable Components
This distinction is critical for EPR classification and costs:
Separable Components
Materials that a consumer can easily separate before disposing of them:
- A plastic cap on a glass bottle — the cap lifts off
- A paper label on a plastic bottle — the label peels off
- A plastic window in a cardboard box — the window pops out
- A foil seal under a plastic cap — the seal peels away
Rule: Report each component separately by its own material type.
Non-Separable Composites
Materials that are bonded together and cannot be separated:
- A Tetra Pak carton (card + PE + aluminium layers)
- A PE-lined coffee cup (paper + plastic lining)
- A laminated pouch (multiple plastic layers + aluminium)
- A metalised film wrapper (plastic + metal coating)
Rule: Report as a single composite item, classified by the predominant material by weight.
How to Classify Multi-Material Packaging
Step 1: Can the consumer easily separate the materials?
- Yes → Report each material separately (separate weights, separate material classifications)
- No → Go to Step 2
Step 2: What is the predominant material by weight?
For non-separable items, classify by the material that makes up the largest proportion by weight:
| Predominant Material | Classification | Fee Rate (approx.) |
|---|---|---|
| Paper/card | Fibre-based composite | £461/t |
| Plastic | Plastic (non-recyclable) | £420-£461/t |
| Aluminium | Aluminium composite | £230-£461/t |
| Other | Other composite | Varies |
Important: Fibre-based composites always attract the highest rate (£461/t), regardless of the secondary material.
Decision Tree Example
Product: Cardboard box with a clear plastic window
- Can the consumer separate the window from the card? Yes — the window is a separate, removable piece
- Report the cardboard as paper/card (£215/t) and the plastic window as plastic (£360-380/t)
Product: Tetra Pak juice carton
- Can the consumer separate the layers? No — they are bonded
- Predominant material? Paper/card (approximately 75% by weight)
- Classify as fibre-based composite (£461/t)
EPR Fee Implications
The cost difference between separable and non-separable classification is substantial:
Example: Cardboard Box with Plastic Window
| Classification Method | Tonnage | Fee | Total |
|---|---|---|---|
| Separable (correct for pop-out window) | |||
| — Cardboard: 50 tonnes | 50t | £215/t | £10,750 |
| — Plastic window: 5 tonnes | 5t | £360/t | £1,800 |
| Total (separable) | 55t | £12,550 | |
| Composite (if bonded together) | |||
| — Fibre composite: 55 tonnes | 55t | £461/t | £25,355 |
The difference is over £12,000 — more than double — on just 55 tonnes of packaging. Getting the classification right matters enormously.
For all fee rates, see the EPR fees by material type guide.
Common Multi-Material Examples
Separable (Report Each Material Separately)
| Item | Material 1 | Material 2 |
|---|---|---|
| PET bottle + PP cap | PET plastic | PP plastic |
| Glass jar + metal lid | Glass | Steel/aluminium |
| Cardboard box + separate plastic tray | Paper/card | Plastic |
| Aerosol can + plastic overcap | Steel/aluminium | Plastic |
| Cardboard sleeve on plastic pot | Paper/card | Plastic |
Non-Separable (Report as Composite)
| Item | Classification | Fee Rate |
|---|---|---|
| Tetra Pak carton | Fibre-based composite | £461/t |
| Coffee cup (PE-lined) | Fibre-based composite | £461/t |
| Laminated pouch | Plastic composite | £461/t |
| Metalised film | Plastic composite | £420/t |
| Composite can (Pringles-style) | Fibre-based composite | £461/t |
| Blister pack (PVC/aluminium) | Plastic composite | £461/t |
Reporting Multi-Material Packaging
For Separable Items
- Physically separate each component
- Weigh each material individually
- Report under each material’s classification
- Link to the same product in your records for traceability
For Non-Separable Items
- Weigh the complete item as one unit
- Determine the predominant material by weight
- Report as a composite under the predominant material classification
- Do not attempt to split layer weights — report total weight as composite
For detailed reporting, see how to report packaging data to DEFRA.
Reducing Multi-Material EPR Costs
1. Make Components Separable
If your packaging has a bonded multi-material construction, investigate whether it can be redesigned with separable components. For example:
- Bonded plastic window in card → Pop-out plastic window in card (separable)
- Laminated card → Uncoated card with a separate plastic liner
2. Switch to Mono-Material
Eliminate the multi-material problem entirely:
- PE-lined cup → Aqueous-coated paper cup
- Laminated pouch → Mono-PE pouch
- Composite can → Pure cardboard tube with peel-off metal end
3. Reduce the Number of Materials
Fewer materials in a composite mean simpler waste processing:
- Card/PE/aluminium carton → Card/PE carton (remove aluminium layer)
- PET/PE/EVOH pouch → Mono-PE pouch
4. Choose Lower-Fee Materials for Components
When multi-material is unavoidable, choose lower-fee materials for separable components:
- PP caps instead of metal caps on glass jars (PP = £360/t, glass is already £192/t)
- Paper labels instead of plastic shrink sleeves (£215/t vs £360/t)
Getting Started
- Audit your multi-material packaging — list every item with more than one material
- Classify as separable or composite using the decision tree
- Calculate fees under correct classification
- Identify redesign opportunities to reduce costs
- Report accurately through DEFRA’s RPD portal
Use the EPR fee calculator and explore our compliance tools.