UK Packaging EPR, Year Two: What Comes After the 1 October 2026 Deadline, and What RAM 2027 Changes
What Did UK Packaging EPR Require by 1 October 2026?
By 1 October 2026, a large producer under UK packaging EPR had to report its packaging data for 1 January to 30 June 2026, according to the GOV.UK deadlines page, last updated on 19 August 2026 and read again on 5 October 2026. By the same date, a large producer had to submit its application to register for 2027 and pay its registration fee, according to the GOV.UK registration guidance.
UK packaging EPR is the extended producer responsibility scheme for packaging that applies in England, Wales, Scotland and Northern Ireland under UK Statutory Instrument 2024 No. 1332. PackUK is its scheme administrator, according to its GOV.UK page. Year two is the 2026 to 2027 financial year of the scheme, according to the PackUK modulation statement.
This article is for EU brands, importers, distributors and online sellers supplying the UK; our guides to PPWR producer registration and eco-modulated EPR fees cover the EU side.
Key Facts
- Large producers had to report packaging data for 1 January to 30 June 2026 and apply to register for 2027 by 1 October 2026, according to the GOV.UK deadlines page updated on 19 August 2026.
- Large producers report packaging data for 1 July to 31 December 2026, and small producers for the whole of 2026, by 1 April 2027, according to the same page.
- PackUK intends to issue the initial notice of liability for the 2026 to 2027 assessment year by the end of November 2026, according to its operational plan updated on 10 August 2026.
- RAM 2027 applies to packaging supplied in 2027, with submission deadlines of 1 October 2027 and 1 April 2028, according to PackUK on 1 July 2026, in an announcement last updated on 11 August 2026.
- Regulation (EU) 2025/40 applies to all packaging, regardless of material, whether household, commercial or industrial, under Article 2(1).
- Our dated PPWR referential (baseline reviewed 3 October 2026) confirms the fifth line; the UK lines are read on GOV.UK on 5 October 2026.
Who Is a Large Producer Under UK Packaging EPR?
A large producer under UK packaging EPR is an organisation established in the UK that carries out a packaging activity, supplied or imported more than 50 tonnes of packaging in the UK in the previous calendar year and has an annual turnover of more than £2 million, according to the GOV.UK threshold table, last updated on 19 August 2026.
| Packaging weight | £1 million or less annual turnover | From £1 million to £2 million annual turnover | More than £2 million annual turnover |
|---|---|---|---|
| Less than 25 tonnes | No obligation | No obligation | No obligation |
| From 25 tonnes to 50 tonnes | No obligation | Small producer | Small producer |
| More than 50 tonnes | No obligation | Small producer | Large producer |
For 2026 data, the tonnage counted is the packaging supplied or imported in 2025, and the turnover comes from the last accounts available before 7 April 2026, according to the same guidance. An organisation is established in the UK if its registered office, head office or principal place of business is there, or if it has a UK branch, warehouse, PO box, returns address or other UK postal address.
GOV.UK lists seven packaging activities, including importing goods in packaging, owning an online marketplace supplying packaging in the UK from outside the UK, and selling filled packaging to an end user. See our article on online marketplaces for the PPWR side.
Which UK Packaging EPR Dates Follow 1 October 2026?
After 1 October 2026, the dated UK packaging EPR steps on official pages are the initial year two notice of liability, intended by PackUK by the end of November 2026, the reporting and registration date of 1 April 2027, and the RAM 2027 reporting dates of 1 October 2027 and 1 April 2028, according to GOV.UK and PackUK.
| Date | Who | What | Status on 5 October 2026 |
|---|---|---|---|
| 1 September 2026 | Producers who pay pEPR fees | Resubmission of 2025 packaging data | Passed |
| 1 October 2026 | Large producers | Packaging data for 1 January to 30 June 2026, and application to register for 2027 with the registration fee | Passed |
| By the end of November 2026 | Producers who pay pEPR fees | Initial notice of liability for the 2026 to 2027 assessment year | Intention stated by PackUK |
| 1 January 2027 | Large producers paying household packaging waste disposal fees | RAM 2027 covers household packaging supplied from this date | Published guidance |
| 1 April 2027 | Large producers | Packaging data for 1 July to 31 December 2026 | Published deadline |
| 1 April 2027 | Large producers whose only packaging activity is selling filled packaging to end users | Application to register for 2027 | Published deadline |
| 1 April 2027 | Small producers | Packaging data for 1 January to 31 December 2026; registration and registration fee, due each year by 1 April | Published deadline |
| 1 October 2027 and 1 April 2028 | Large producers | Packaging data for the first and second halves of 2027, assessed with RAM 2027 | Announced by PackUK |
Large producers register each year and pay the applicable fees by 1 October, according to the GOV.UK deadlines page; the registration guidance lists dates up to registration for 2027 only. Packaging data is uploaded as a CSV file to the report packaging data service, according to the reporting file guidance.
What Should a Large Producer Do After Missing 1 October 2026?
A producer that missed a UK packaging EPR deadline should contact its environmental regulator, according to the GOV.UK deadlines page. A large producer that did not submit its 2027 registration and pay its registration fee by 1 October 2026 must pay a late fee and may be subject to enforcement action, according to the GOV.UK registration guidance.
The environmental regulators named by GOV.UK are the Environment Agency in England, Natural Resources Wales, the Scottish Environment Protection Agency and the Northern Ireland Environment Agency. Resubmissions of 2025 data made after 1 September 2026 do not affect Notices of Liability or disposal fees, according to PackUK.
What Does Year Two Change for Household Packaging Fees?
Year two of UK packaging EPR brings the first household packaging waste disposal fees modulated by recyclability, calculated on packaging supplied in 2025, according to the PackUK modulation statement of 17 February 2026. The base fee reflects an amber rating: packaging rated red pays a higher price per tonne and packaging rated green a lower one.
| Rating | Meaning in the RAM 2027 overview | Fee effect under the PackUK modulation statement |
|---|---|---|
| Green | Widely recyclable in the current UK infrastructure | Lower: an equal percentage discount per tonne |
| Amber | Collection, sortation or reprocessing challenges, or some secondary material loss | No change: the base fee |
| Red | Specifications that make it difficult to recycle at scale | Higher: multiplied by a modulation factor |
Household packaging is primary or shipment packaging other than the exceptions of regulation 8 of SI 2024/1332, such as packaging for a business product not reasonably likely to be disposed of in a household or public bin. Waste disposal fees are paid only for household packaging, commonly binned packaging and glass household drinks containers, according to the GOV.UK fees guidance. A small producer does not pay waste disposal fees, according to the small producer guidance.
PackUK stated on 17 July 2026 that it would publish confirmed producer fees for 2026 to 2027 and issue Notices of Liability later this calendar year; no confirmed year two fees appear on the GOV.UK pages read on 5 October 2026. PackUK sends a notice of liability for each assessment year, based on the packaging supplied in the previous calendar year, according to the GOV.UK notice of liability guidance updated on 26 August 2026. Payment is usually in quarterly instalments, with the details set out in the notice, and producers have 50 calendar days to pay, as in year one, according to PackUK.
Does Fee Modulation Change After Year Two?
The red fee multiplier of UK packaging EPR increases in year three, 2027 to 2028, and again in year four, 2028 to 2029, according to the illustrative fees published by PackUK and Defra on 16 December 2025. The additional funding from the increased red fee discounts green fees, so that the total cost of the scheme remains fixed, according to the same document.
Those figures are illustrative: no confirmed year three fees appear on the GOV.UK pages read on 5 October 2026.
What Is RAM 2027 and What Does It Change?
RAM 2027 is the recyclability assessment methodology that large producers paying household packaging waste disposal fees must use for household packaging supplied from 1 January to 31 December 2027, according to guidance published by PackUK and Defra on 1 July 2026 and last updated on 20 August 2026. RAM version 1.1 remains the methodology for 2026.
The recyclability assessment methodology is the method that PackUK designs, maintains and publishes to assess the recyclability of household packaging. PackUK describes the changes in RAM 2027 as refinements to material rules, definitions, assessment guidance, structure and usability, according to its announcement of 1 July 2026.
Packaging can be reported as amber if producers have evidence that it is collected using a take-back scheme and successfully recycled, according to the RAM 2027 overview.
How Does RAM 2027 Rate an Item of Packaging?
RAM 2027 rates an item of packaging or a component red, amber or green at four stages: collection, sortation, reprocessing and application, according to the RAM 2027 overview. An item is green only if green at every stage, amber if green or amber at every stage, and red if red at any stage, under the materials assessment guidance.
Packaging is reported as red if the producer has no evidence that it meets an amber or green rating, under the same guidance. Producers do not submit that evidence, but they keep records for 7 years and provide them to the regulators on request.
Is UK Packaging EPR the Same as EPR Under the PPWR?
No. UK packaging EPR rests on the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, while EPR under Regulation (EU) 2025/40 sits in its Articles 44, 45 and 46. The two regimes define the producer differently, keep separate registers and set different reporting dates.
| Question | UK packaging EPR | EPR under Regulation (EU) 2025/40 |
|---|---|---|
| Producer | Established in the UK, carrying out a packaging activity, above the tonnage and turnover thresholds | Established in a Member State and first making packaging available there, or established in a Member State or a third country and making it available directly to end users in another Member State, under Article 3(1)(15) |
| Registration | Each year, with the UK environmental regulator | In each Member State of first making available, under Article 44(2) |
| Reporting | Every six months for large producers, yearly for small ones | By 1 June for each full preceding calendar year, under Article 44(7) |
| Recyclability scale | RAM ratings red, amber and green | Recyclability performance grades A, B or C, under Article 6(3) |
The PPWR is Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste. Under Article 6(3) of that Regulation, the manufacturer assesses packaging recyclability on the basis of the delegated acts adopted under Article 6(4) and the implementing acts adopted under Article 6(5), not with the RAM. From 1 January 2030 or 24 months from the entry into force of those delegated acts, whichever is the latest, packaging must be recyclable within grades A, B or C to be placed on the market. Our role-by-role PPWR checklist covers what applies now.
What Does the Referential Not Confirm?
Our dated PPWR referential (baseline reviewed 3 October 2026) covers Regulation (EU) 2025/40 only and confirms one statement here, the scope of Article 2(1). The points below are read on the Official Journal text or the official UK page cited.
- Articles 3(1)(15), 6(3), 44(2) and 44(7), the titles of Articles 44 to 46 and the Regulation's title and date, read on the Official Journal text, which never mentions the RAM.
- UK statements, read on GOV.UK and legislation.gov.uk on 5 October 2026; nothing here is legal advice.
- Not found on the pages read: confirmed year two or year three fees, the fee year using RAM 2027 ratings, registration dates after registration for 2027, the tonnage and turnover years for 2027 data, and a rule-by-rule list of RAM changes.
- Not assessed here: whether and how Regulation (EU) 2025/40 applies in Northern Ireland.
Frequently Asked Questions
Is an EU company without a UK address an obligated producer?
Not under the GOV.UK conditions, which require establishment in the UK. A UK branch, warehouse, PO box or returns address counts as establishment, and importing goods in packaging is itself a packaging activity.
Did RAM 2027 apply to the data due on 1 October 2026?
No. RAM 2027 applies to packaging supplied in 2027, according to PackUK. The report due on 1 October 2026 covered 1 January to 30 June 2026 and used RAM version 1.1.
Is there a UK reporting date between 1 October 2026 and 1 April 2027?
No reporting or registration date between those two dates appears on the GOV.UK deadlines page read on 5 October 2026. PackUK intends to issue the initial year two notice of liability by the end of November 2026.
How PPWR Connect Helps
PPWR Connect is software: it does not submit data to the report packaging data service, is not a compliance scheme and does not rate packaging for the RAM. A packaging item can record the markets it is placed on outside the EU, the United Kingdom included. A packaging version can carry its UK RAM rating, declared by you. EPR declarations can be generated per UK semester and record what they were computed from. To see which items reach the UK market, start with our PPWR compliance software or the PPWR readiness assessment.
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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.