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.

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.

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

Explore our EPR glossary for definitions of key terms, or check your obligation status with our free compliance checker.

Start your free trial and see how applying the waste hierarchy can reduce your EPR costs.

The Packaging Waste Hierarchy and EPR Compliance: A Practical Guide

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