COSTS are set to rise for any business that handles packaging, with the introduction of eco-modulated fees coming to the Extended Producer Responsibility (EPR) regulations this April.
This comes one year on from the launch of the EPR guidance, as businesses switched over from the 2007 packaging regulations on 1 April 2025.
As the regulations continue to tighten and evolve, Connor Sharkey, regulatory and specifications manager at Food Nutrition Partners, outlines the key changes food manufacturing businesses should know about this April, and how they can prepare.
What do the latest EPR changes mean for food and drink manufacturers?
For all food manufacturers, producer responsibility laws in the UK have guided operations for years, yet this is a significant update regarding packaging with costly implications if not adhered to.
As part of the updated EPR guidance, an ‘eco-modulated’ fee structure has been introduced. This uses the Recyclability Assessment Methodology (RAM), to charge a business based on the recyclability of its packaging, with higher fees for materials that are harder to recycle and lower fees for “green-rated” packaging. These fees are set to increase substantially over the next three years, and from 2026 some of the least environmentally friendly packaging could cost more than double the base fee already.
While the full guidance can be read on the government’s website, there are a few key changes that look to effect most food manufacturing businesses. Those using flexible plastics or complex multi-layered packaging for example which fall into the ‘red/amber’ RAM category, could see substantial cost increases after April. I’d recommend reviewing all your current packaging materials now, ideally alongside reliable suppliers for accuracy and to spot opportunities for improvement.
While making any changes to materials used, you also need to make sure your packaging continues to protect the food, preserves nutrition (especially vitamins), and comply with legal requirements, making this an opportunity for innovation as well as cost saving.
Which packaging types are most affected?
Flexible plastics and complex composite materials are expected to see the biggest cost increases. Smaller businesses may feel this impact more, as high-barrier, recyclable materials often come at a premium, whereas larger companies can more easily absorb these costs. Over time, and driven by this legislation, I expect to see these materials become more accessible to SMEs, spreading widely across the industry.
How will eco-modulated EPR fees influence packaging design in the future?
Over the next few years, packaging may become smaller, lighter and simpler. Decisions about gloss, matte finishes and ink colors could be influenced by recyclability scores. This shift is likely to align with consumer preferences, as 34% of UK consumers prioritise recyclable or biodegradable packaging (YouGov). As a result, brands that proactively adapt their packaging strategies may gain a competitive advantage in both compliance and consumer perception.
How can manufacturers reduce their EPR costs?
- Audit your packaging: Review every material currently used and be aware that supplier-provided ratings are more reliable than DIY assessments.
- Innovate packaging design: Consider downsizing, adjusting finishes or ink colors, or optimising material layers. Any changes you make that improve recyclability can lower fees.
- Collect evidence and track ratings: Keep documentation on recyclability (RAM ratings) to withstand potential audits. Especially if you consistently achieve a green rating, reducing the fees you pay.
What is your one key piece of advice to remain compliant?
Act as if you are going to be audited. Always ensure your data is accurate, your RAM evidence is thorough and your packaging choices are well-researched. That way, your business can stay compliant while minimising costs.