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Guide 7 min read

Paper and Card Packaging EPR: UK Compliance Guide

EPR Compliance Team

Table of Contents


Key Takeaways

  • Paper and card packaging attracts the lowest non-metal fee rate at approximately £215 per tonne.
  • Pure paper/card is one of the most cost-effective materials under EPR due to high recyclability and established infrastructure.
  • Coated, laminated, or waxed card may be classified as fibre-composite at £461/tonne — more than double the paper rate.
  • The distinction between paper/card and fibre-composite hinges on whether coatings prevent paper recycling.
  • Corrugated cardboard is the UK’s most recycled packaging material with rates exceeding 85%.

Paper and Card Under EPR

Paper and cardboard packaging benefit from some of the most favourable EPR fee rates, reflecting the material’s excellent recyclability. The UK has a well-established paper and card recycling infrastructure, with collection rates among the highest in Europe.

For businesses, paper and card packaging represents a cost-effective choice under EPR. However, it is essential to understand when paper/card crosses the line into fibre-based composite territory — which attracts the highest fee rate of any packaging material.

For EPR basics, see what packaging EPR is.

Types of Paper and Card Packaging

Paper

  • Paper bags — retail and industrial
  • Tissue paper — wrapping and protective
  • Greaseproof paper — food wrapping
  • Kraft paper — wrapping, void fill
  • Labels — self-adhesive paper labels
  • Paper tape — for sealing boxes

Cardboard (Solid Board)

  • Printed cartons — retail product boxes
  • Folding boxboard — lightweight product boxes
  • Gift boxes — presentation packaging
  • Shelf-ready displays — retail POS packaging

Corrugated Cardboard

  • Single wall — standard shipping boxes
  • Double wall — heavy-duty transit
  • Triple wall — industrial transit
  • Dividers and inserts — internal packaging
  • Edge protectors — corner and edge guards

EPR Fee Rates

Paper/Card TypeFee per tonne (approx.)Notes
Paper (uncoated)£215Bags, wraps, tissue
Cardboard (uncoated)£215Boxes, cartons
Corrugated cardboard£215Transit packaging
Paper labels£215Self-adhesive labels
Fibre-based composite£461Coated/laminated card

The critical distinction is between pure paper/card (£215/t) and fibre-based composite (£461/t). See the fibre composite packaging guide for details.

For all rates, see the EPR fees by material type guide.

When Paper Becomes Fibre Composite

Classified as Paper/Card (£215/t)

  • Printed cardboard — printing ink does not change the classification
  • Varnished cardboard — thin UV or water-based varnish that does not prevent recycling
  • Cardboard with removable plastic components — e.g., a box with a pop-out plastic window
  • Recycled cardboard — recycled content does not change classification
  • Embossed or textured card — surface treatment does not affect classification

Classified as Fibre Composite (£461/t)

  • PE-coated card — polyethylene lining bonded to paper (coffee cups, liquid cartons)
  • Waxed cardboard — heavy wax coating preventing paper recycling
  • Laminated card — plastic film bonded to cardboard surface
  • Metallised card — aluminium coating on card
  • Card with bonded plastic window — window cannot be separated from the card

The Test

The question is: does the coating or additional material prevent the packaging from being recycled through standard paper/card recycling?

  • If yes → fibre-based composite (£461/t)
  • If no → paper/card (£215/t)

If in doubt, check with your packaging supplier or a waste management specialist.

Reporting Paper and Card

What to Report

  1. Total weight of paper/card packaging by category (primary, secondary, transit)
  2. Separate fibre composites from pure paper/card
  3. Include all paper components — boxes, labels, tissue, inserts, tape
  4. Report nation data (large producers) — where packaging ends up across UK nations

Common Items Often Missed

  • Paper tape — classified as paper packaging
  • Paper labels on glass or plastic containers — paper packaging
  • Tissue paper in product wrapping — paper packaging
  • Instruction leaflets packed with products — packaging (not a product)
  • Paper void fill — crumpled kraft paper used as protective fill
  • Cardboard shelf-ready displays — packaging

For reporting guidance, see how to report packaging data to DEFRA.

Reducing Costs

1. Ensure Correct Classification

The biggest cost impact is ensuring paper/card packaging is not incorrectly classified as fibre composite. Review your packaging to confirm which items are truly composite vs pure paper/card.

2. Lightweighting

Paper and card packaging can be specified in lighter grades:

  • Lighter flute profiles for corrugated (e.g., E-flute instead of B-flute for lighter items)
  • Thinner board grades for cartons
  • Optimised paper weights for bags and wraps

3. Right-Sizing

Match box sizes to products to reduce cardboard usage. Automated box-sizing solutions can reduce corrugated usage by 20-30%.

4. Remove Coatings Where Possible

If you use laminated or PE-coated card, evaluate whether the coating is genuinely needed. Switching to uncoated card drops the fee from £461 to £215 per tonne.

5. Replace Other Materials with Paper

Paper is one of the cheapest materials under EPR. Where performance allows, switching from plastic to paper reduces both the fee rate and the material’s environmental impact:

  • Plastic bags → paper bags
  • Polybags → paper wraps
  • Plastic void fill → paper void fill
  • EPS inserts → moulded pulp inserts

Getting Started

  1. Catalogue all paper/card packaging in your supply chain
  2. Separate pure paper/card from fibre composites — this affects your fee rate
  3. Weigh and report by the correct classification
  4. Identify lightweighting opportunities
  5. Register with a compliance scheme and submit data to DEFRA

Use the EPR fee calculator and visit our pricing page.

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