Table of Contents
- What Is the Waste Hierarchy?
- The Five Levels Applied to Packaging
- How the Waste Hierarchy Connects to EPR Fees
- Prevention: Reducing Packaging at Source
- Reuse: Refillable and Returnable Systems
- Recycling: Designing for End-of-Life
- Recovery and Disposal: The Last Resorts
- Practical Steps for Your Business
What Is the Waste Hierarchy?
The waste hierarchy is a framework ranking waste management options from most to least environmentally preferable. It is enshrined in UK law through the Waste (England and Wales) Regulations 2011 and equivalent legislation in Scotland and Northern Ireland. DEFRA’s EPR guidance expects producers to apply these principles when making packaging decisions.
The hierarchy has five levels, ordered from best to worst:
- Prevention — avoid creating waste in the first place
- Reuse — use materials again for the same or different purpose
- Recycling — process waste materials into new products
- Recovery — extract energy from waste (incineration with energy recovery)
- Disposal — landfill or incineration without energy recovery
Under packaging EPR, businesses are expected to apply the waste hierarchy when making packaging decisions. The reformed EPR scheme reinforces this through fee modulation — packaging higher up the hierarchy (more recyclable, less wasteful) attracts lower fees.
The Five Levels Applied to Packaging
Level 1: Prevention
The most effective way to reduce your EPR obligations is to use less packaging. Every tonne of packaging you eliminate is a tonne you do not need to report or pay fees on.
Prevention includes:
- Removing unnecessary packaging layers (double-boxing, excess void fill)
- Reducing packaging material weight (thinner films, lighter bottles)
- Right-sizing packaging to fit products without wasted space
- Eliminating non-essential packaging components (unnecessary inserts, overwraps)
Level 2: Reuse
Reusable packaging systems keep materials in circulation without reprocessing. Examples include:
- Refillable glass bottles (common in milk delivery)
- Returnable transit packaging (reusable crates, pallets)
- Refillable beauty product containers
- Reusable e-commerce packaging systems
Reusable packaging that is hired or loaned is an obligated activity under EPR, but the per-use packaging weight is lower than single-use alternatives.
Level 3: Recycling
Designing packaging that can be effectively recycled at end of life. This means:
- Using mono-materials rather than multi-material combinations
- Choosing materials with established recycling infrastructure
- Avoiding contaminants that disrupt recycling (non-detectable pigments, non-separable components)
- Providing clear recycling instructions to consumers
Level 4: Recovery
When packaging cannot be recycled, energy recovery through incineration captures some value from the material. This is preferable to landfill but far below recycling in the hierarchy.
Level 5: Disposal
Landfill and incineration without energy recovery are the least desirable outcomes. Packaging sent to landfill represents a complete loss of material value and contributes to environmental harm.
How the Waste Hierarchy Connects to EPR Fees
The reformed EPR scheme creates a direct financial link between the waste hierarchy and packaging costs:
Current Year (2025-2026)
Fee rates already reflect the hierarchy to some extent. Materials with higher recycling rates and lower management costs (glass, paper/card) have lower fees. Materials that are harder to manage (plastic, fibre-based composite) have higher fees.
| Material | Fee/Tonne | Recycling Difficulty |
|---|---|---|
| Glass | £192 | Low — widely recycled |
| Paper/card | £196 | Low — widely recycled |
| Steel | £259 | Low-medium |
| Aluminium | £266 | Low-medium |
| Wood | £280 | Medium |
| Plastic | £423 | Medium-high |
| Fibre composite | £461 | High |
From 2026-2027 (Fee Modulation)
Fee modulation will sharpen this connection significantly. Within each material category, packaging that is easier to recycle will pay less than packaging that is harder to recycle. This means:
- Mono-material recyclable packaging → lowest fees within its material category
- Standard recyclable packaging → base-level fees
- Hard-to-recycle packaging → premium fees above the base rate
- Non-recyclable packaging → highest fees
For details on how modulation works, read our modulated fees guide.
Prevention: Reducing Packaging at Source
Prevention offers the greatest EPR cost savings because it reduces your reportable tonnage entirely. Practical approaches:
Lightweighting
Reduce the amount of material in each packaging item without compromising protection. A shipping box reduced from 500g to 400g saves 20% of the EPR fee for that item across your entire volume.
Right-Sizing
Match packaging size to product size. E-commerce businesses often use a limited range of box sizes, leading to oversized boxes and excessive void fill. Right-sizing reduces both box weight and void fill requirements.
Eliminating Redundancy
Review every layer of packaging and ask whether it adds value. Does the product need both a polybag and tissue paper and a branded box? Could one layer serve the functions of two?
Concentrated Products
For food and drink or beauty businesses, concentrated product formats (concentrated cleaning products, solid cosmetics) require less packaging per unit of product.
Reuse: Refillable and Returnable Systems
Reuse systems are gaining momentum across several sectors:
Transit Packaging Reuse
Switching from single-use cardboard transit cases to returnable plastic crates reduces transit packaging weight over time. Many wholesale and distribution businesses already use returnable systems.
Consumer Refill Systems
Refillable beauty containers, refillable household product bottles, and milk bottle return schemes all reduce single-use packaging. Under EPR, the initial container is reportable, but refill pouches or bulk refills typically use less packaging per unit of product.
Reusable E-commerce Packaging
Startups are offering reusable mailing bags and boxes that customers return for reuse. While adoption is still early, these systems could significantly reduce shipment packaging volumes for online sellers. WRAP publishes research and case studies on reuse systems across various sectors.
Recycling: Designing for End-of-Life
If packaging cannot be prevented or reused, designing it for effective recycling is the next best option:
Choose Mono-Materials
Multi-material packaging is difficult to recycle because different materials require different reprocessing methods. A paper pouch with a plastic lining cannot go through paper or plastic recycling. Choose single-material alternatives wherever possible.
Avoid Problem Materials
Some materials actively contaminate recycling streams:
- Black plastic is invisible to sorting sensors
- PVC contaminates PET recycling
- Multi-layer flexible films cannot be separated
Use Widely Recycled Formats
Design packaging using materials and formats that are already widely collected and recycled in the UK — clear PET, HDPE, standard corrugated cardboard, glass, aluminium, and steel.
Make Separation Easy
If your packaging has multiple components (such as a card sleeve around a plastic tray), make sure consumers can easily separate them. Clear instructions help ensure materials enter the correct waste stream.
Recovery and Disposal: The Last Resorts
Some packaging waste inevitably ends up being recovered for energy or disposed of in landfill. Under EPR, the fees you pay help fund better collection and recycling infrastructure to minimise this. However, businesses should aim to minimise the proportion of their packaging that ends up in these lowest-value waste streams.
Packaging that consistently ends up in residual waste (landfill or incineration) will face the highest modulated fees from 2026-2027 — creating a strong financial incentive to design it out of your packaging portfolio.
Practical Steps for Your Business
- Audit your packaging against the waste hierarchy — for each item, ask “can we prevent this, reuse it, or make it more recyclable?”
- Calculate the cost impact — use our fee calculator guide to model the financial impact of packaging changes
- Prioritise high-volume items — focus on your heaviest packaging types first, where changes have the biggest tonnage and cost impact
- Engage suppliers — share your waste hierarchy goals with packaging suppliers and ask for alternative specifications
- Track your progress — use our platform to monitor how packaging changes affect your reported tonnage and estimated fees over time
Measuring Your Progress Up the Hierarchy
Applying the waste hierarchy is not a one-off exercise — it requires ongoing measurement and improvement. Here is how to track your business’s progress.
Establish a Packaging Baseline
Before making changes, document your current packaging portfolio:
| Metric | How to Measure | Why It Matters |
|---|---|---|
| Total packaging weight (tonnes) | Sum of all packaging by material type | Your overall EPR fee exposure |
| Packaging weight per order/unit | Total weight divided by order volume | Identifies lightweighting opportunities |
| Material mix (% by weight) | Proportion of each material in your portfolio | Shows reliance on high-fee materials |
| Recyclability rate | % of packaging that is widely recyclable | Predicts modulated fee impact |
| Number of packaging components | Count of distinct packaging items | Complexity indicator |
Set Reduction Targets
Based on your baseline, set specific, measurable targets aligned to the waste hierarchy:
- Prevention target: “Reduce total packaging weight per order by 15% within 12 months”
- Material switch target: “Replace 3 tonnes of plastic packaging with paper alternatives by Q3”
- Recyclability target: “Ensure 90% of packaging portfolio is widely recyclable before modulation takes effect”
Track Cost Savings
Every packaging change has a quantifiable EPR fee impact. When you eliminate 2 tonnes of plastic packaging, that saves £846 per year at £423/tonne. When you switch 5 tonnes from plastic to paper, that saves £1,135 per year (£423 minus £196 = £227 per tonne saved, times 5 tonnes). Our platform tracks these savings automatically as you update your packaging data.
Case Studies: Waste Hierarchy in Practice
Case Study 1: E-commerce Fashion Brand
Challenge: A mid-sized fashion retailer used individual polybags for every garment, plastic air pillows for void fill, and oversized cardboard boxes.
Changes made:
- Prevention: Eliminated polybags for non-delicate items (denim, outerwear) — removed 1.8 tonnes of plastic per year
- Prevention: Right-sized shipping boxes from 3 sizes to 7 sizes — reduced cardboard by 4 tonnes per year
- Material switch: Replaced plastic air pillows with recycled paper void fill — moved 1.2 tonnes from plastic (£423/t) to paper (£196/t)
Result: Annual EPR fee reduction of approximately £2,400, plus reduced packaging procurement costs.
Case Study 2: Food Manufacturer
Challenge: A food and drink producer used black plastic trays for ready meals, multi-layer film lids, and excessive corrugated transit packaging.
Changes made:
- Recycling improvement: Switched from black plastic trays to clear rPET trays — same material weight but dramatically improved recyclability
- Prevention: Redesigned transit cases to use 20% less corrugated board through improved structural design
- Reuse: Introduced returnable plastic crates for deliveries to major retailer customers, replacing single-use corrugated cases
Result: No change in Year 1 base fees (material type unchanged), but positioned for significant savings when modulated fees take effect. Transit packaging reduced by 8 tonnes per year.
Regulatory Expectations Around the Waste Hierarchy
The DEFRA EPR guidance and the Waste (England and Wales) Regulations 2011 both require businesses to apply the waste hierarchy when making decisions about packaging. While there is currently no specific enforcement mechanism for hierarchy compliance (beyond the fee structure), businesses should be aware that:
- Audit questionnaires may ask what steps you have taken to reduce packaging waste
- Industry benchmarking will become more common as DEFRA collects data on packaging formats across sectors
- Consumer and retail pressure increasingly favours brands that demonstrably reduce packaging
- Fee modulation from 2026-2027 translates hierarchy principles into direct financial consequences
WRAP publishes sector-specific guidance on packaging reduction, reuse, and recyclability that can help you develop your waste hierarchy strategy.
Explore our EPR glossary for definitions of key terms, or check your obligation status with our free compliance checker. Learn about UK recycling targets and how they drive EPR fees, or view our pricing plans to get started with our platform.
Start your free trial and see how applying the waste hierarchy can reduce your EPR costs.