Table of Contents
- Plastic Packaging Under EPR
- Plastic Types and EPR Classifications
- EPR Fee Rates for Plastic
- Modulated Fees and Recyclability
- Plastic Packaging Tax Overlap
- How to Report Plastic Packaging
- Reducing Plastic EPR Costs
- Key Takeaways
Key Takeaways
- Plastic packaging attracts some of the highest EPR fees at £360-£461 per tonne, depending on the plastic type and recyclability.
- Non-recyclable plastics (PVC, black plastic, multi-layer laminates) attract the highest modulated fee rates.
- The Plastic Packaging Tax (£210.82/tonne) applies separately to plastic packaging with less than 30% recycled content — this is in addition to EPR fees.
- Mono-material recyclable plastics (clear PET, natural HDPE, PP) attract lower fees than multi-material or non-recyclable alternatives.
- Switching from multi-layer to mono-material plastics is the single most effective strategy for reducing plastic EPR costs.
Plastic Packaging Under EPR
Plastic is the most scrutinised packaging material under the UK’s EPR regime. It attracts higher fees than paper, glass, or metal because of its lower recycling rates and higher environmental impact when improperly disposed of.
For UK businesses, plastic packaging represents the largest EPR cost driver in most product categories. Understanding which plastic types attract which fees — and how to optimise your packaging — is essential for managing compliance costs.
For EPR fundamentals, see what packaging EPR is.
Plastic Types and EPR Classifications
Not all plastics are treated equally under EPR. The key classifications are:
Widely Recyclable Plastics
- PET (polyethylene terephthalate) — clear bottles, thermoformed trays
- HDPE (high-density polyethylene) — milk bottles, detergent bottles
- PP (polypropylene) — food tubs, caps, pots
These attract lower modulated fees because they are collected and recycled through kerbside systems.
Recyclable but Limited Collection
- LDPE/PE film — carrier bags, stretch wrap, bread bags (recyclable through front-of-store collection)
- PS (polystyrene) — yogurt pots (some councils collect, others do not)
Difficult to Recycle / Non-Recyclable
- PVC (polyvinyl chloride) — shrink sleeves, blister packs
- Black plastic — cannot be detected by NIR sorting equipment
- Multi-layer laminates — pouches combining different plastic layers
- EPS (expanded polystyrene) — protective inserts, food containers
- Multi-material composites — plastic combined with aluminium, paper, etc.
These attract the highest EPR fees.
EPR Fee Rates for Plastic
| Plastic Type | Recyclability | Fee per tonne (approx.) |
|---|---|---|
| Clear PET | Widely recyclable | £340 |
| Natural HDPE | Widely recyclable | £340 |
| PP | Widely recyclable | £350 |
| Coloured PET | Recyclable | £360 |
| PE film | Recyclable (limited) | £360 |
| Rigid plastic (generic) | Mixed | £380 |
| PVC | Difficult | £420 |
| EPS | Difficult | £440+ |
| Black plastic | Non-recyclable (NIR) | £440+ |
| Multi-layer laminate | Non-recyclable | £461 |
The exact rates are set by PackUK and reviewed annually. The trend is towards wider fee differentials between recyclable and non-recyclable plastics.
For all material rates, see the EPR fees by material type guide.
Modulated Fees and Recyclability
EPR fees for plastic are modulated — meaning the fee rate depends on how recyclable the packaging is. This is a deliberate policy to incentivise businesses to choose recyclable packaging.
The modulation factors include:
- Material type — some plastics are more easily recycled than others
- Colour — clear and natural colours are preferred; black is penalised
- Format — bottles are more easily recycled than films or trays
- Multi-material construction — combining plastics with other materials increases fees
- Collection availability — packaging collected through kerbside has an advantage
For a full explanation of modulated fees, see EPR modulated fees explained.
Plastic Packaging Tax Overlap
UK businesses face two separate charges on plastic packaging:
| Charge | Rate | Trigger | Paid To |
|---|---|---|---|
| EPR fees | £340-£461/tonne | All plastic packaging placed on market | PackUK |
| Plastic Packaging Tax | £210.82/tonne | Plastic packaging with <30% recycled content | HMRC |
These are cumulative. A business using non-recyclable virgin plastic could pay over £670 per tonne in combined charges.
How to avoid the Plastic Packaging Tax: Use plastic packaging that contains at least 30% recycled content by weight. This completely exempts you from the tax (but not from EPR fees).
For a detailed comparison, see EPR vs Plastic Packaging Tax differences.
How to Report Plastic Packaging
When reporting plastic packaging through DEFRA’s RPD portal, you must:
- Classify by specific plastic type — PET, HDPE, PP, PE, PVC, PS, etc.
- Separate mono-material from multi-material — a PE bag is different from a PE/aluminium pouch
- Weigh each component — bottle, cap, label, seal (each may be a different plastic)
- Report by packaging category — primary, secondary, transit
- Include all plastic packaging — bags, films, trays, bottles, containers, blister packs, foam
Common Plastic Packaging Oversights
- Shrink sleeve labels — often PVC or PETG, reported separately from the bottle
- Caps and closures — usually PP or HDPE, reported separately from PET bottles
- Tamper-evident bands — small but numerous
- Stretch wrap — significant tonnage for distributors
- Air pillows and void fill — PE film, often overlooked
For reporting guidance, see how to report packaging data to DEFRA.
Reducing Plastic EPR Costs
1. Switch from Multi-Layer to Mono-Material
The biggest fee saving comes from moving multi-layer laminates (£461/tonne) to mono-material alternatives (£340-£360/tonne). Mono-PE and mono-PP packaging technology is advancing rapidly.
2. Eliminate PVC
PVC attracts high fees and is increasingly unacceptable to retailers. Replace PVC shrink sleeves with PET or PP alternatives, and PVC blister packs with PET or cardboard.
3. Avoid Black Plastic
Black plastic packaging cannot be sorted by recycling facilities. Switch to clear, white, or natural colours to reduce your fee rate.
4. Lightweighting
Every gram counts when multiplied by millions of units. Work with packaging engineers to specify the minimum wall thickness, film gauge, or tray weight that meets performance requirements.
5. Increase Recycled Content
Using 30%+ recycled content eliminates the Plastic Packaging Tax (£210.82/tonne saving) and may qualify for lower EPR fees as modulation evolves.
6. Switch to Non-Plastic Alternatives
Where feasible, replace plastic with lower-fee materials:
- Plastic film bags → paper bags (£215/tonne)
- Plastic trays → cardboard trays (£215/tonne)
- EPS inserts → moulded pulp (£215/tonne)
- Polybags → paper wraps (£215/tonne)
The Future of Plastic Packaging Fees
EPR fee modulation for plastics is expected to become more granular over time, with bigger differentials between recyclable and non-recyclable formats. The direction is clear: recyclable mono-material plastics will become relatively cheaper, while non-recyclable plastics will become increasingly expensive.
Businesses investing now in packaging redesign will benefit from lower fees in future years.
Getting Started
- Audit your plastic packaging by type, colour, and format
- Identify non-recyclable plastics in your range — these are your cost hot spots
- Calculate your combined EPR + Plastic Tax exposure
- Develop a roadmap to transition to recyclable alternatives
- Track progress using our compliance tools
Use the EPR fee calculator for cost estimates and check the glossary for material classification definitions.