Packaging EPR for Online Retailers: 2026–27 Fees, Rising Red Rates and What Your 3PL Can Change

03/11/2026 | Share:

Every box, mailer and paper fill that leaves your warehouse now has a cost beyond the price you paid for it. Under the UK’s extended producer responsibility (EPR) scheme for packaging, larger businesses pay fees based on how much packaging they place on the market and, from the 2026 to 2027 scheme year, on how recyclable it is.

For online retailers, that matters more than for most. Ecommerce orders use shipment packaging on every parcel, and the choices you make about boxes, mailers and void fill now feed straight into an annual bill.

This guide explains who EPR applies to, how fees are now linked to recyclability, the deadlines coming up in 2027, how responsibility is split when a fulfilment provider packs your orders, and practical ways to reduce what you pay. It is written by Ogden Fulfilment, an ISO 14001-certified fulfilment company in West Yorkshire that packs around 850,000 orders a year for more than 140 brands.

This article is a general guide, not legal or compliance advice. Check your own position using the government’s EPR guidance or with a packaging compliance scheme.

What is packaging EPR?

Extended producer responsibility for packaging makes the businesses that supply packaging pay the cost of collecting and managing it once it becomes household waste. The scheme is run by PackUK, which calculates fees and sends producers a notice of liability each year.

The first fees, often called base fees, were invoiced from October 2025 based on packaging supplied in 2024. The 2026 to 2027 scheme year is the first in which household packaging fees are adjusted, or modulated, according to how recyclable the packaging is.

Does EPR apply to your business?

EPR applies to UK businesses that carry out a packaging activity and meet both size thresholds. You are an obligated producer if you have an annual turnover of £1 million or more and supplied or imported more than 25 tonnes of packaging in the UK in the previous year.

Producers are then split into two groups:

• Large producers have a turnover of more than £2 million and handle more than 50 tonnes of packaging, or handle 25 to 50 tonnes with a turnover of more than £2 million. Large producers report data twice a year and pay waste management fees.
• Small producers have a turnover of £1 million to £2 million and handle more than 25 tonnes. Small producers report data once a year and have lighter obligations.

Packaging activities include supplying goods under your own brand, packing or filling packaging, importing goods in packaging, operating an online marketplace and hiring or lending reusable packaging such as pallets. Even if your business is below the thresholds today, rapid growth can take you over them, so it is worth tracking your packaging weights now.

Shipment packaging: why ecommerce brands are exposed

The EPR rules group packaging into classes: primary, secondary, tertiary and shipment. Shipment packaging is the packaging used to send goods to consumers, including goods sold online. For ecommerce brands, that means every outer box, mailer and protective fill used to ship orders.

Because every online order needs shipment packaging, ecommerce brands tend to supply more packaging per pound of sales than many high street retailers. Oversized boxes, heavy void fill and mixed-material mailers all add weight, and from 2026 to 2027 hard-to-recycle formats also add cost.

How recyclability now changes your fees

From the 2026 to 2027 scheme year, household packaging is rated using PackUK’s Recyclability Assessment Methodology (RAM). Each packaging item is rated green, amber or red:

• Green packaging is readily recyclable and pays a lower fee.
• Amber packaging pays the standard rate, which replaces the old base fee.
• Red packaging is hard to recycle and pays a higher fee.

In 2026 to 2027, red-rated packaging pays 1.2 times the amber fee. Illustrative figures published by PackUK show the red multiplier rising in the following two years, to 1.6 times in 2027 to 2028 and 2.0 times in 2028 to 2029. These later figures are illustrative and may change, but the direction is clear: hard-to-recycle packaging will cost progressively more.

RAM is also being tightened. Under RAM 2027, which applies to household packaging supplied from 1 January 2027, packaging is assessed at four stages: collection, sorting, reprocessing and end use. An item is rated green only if it is green at every stage, and red if it is red at any stage.

Industry bodies have raised concerns about some ratings. For example, fibre-based packaging with more than 5% non-fibre content, such as card with a plastic coating or lining, is charged at the red rate. That catches some packaging that brands think of as paper-based.

Key EPR dates for 2026 and 2027

• By the end of November 2026: PackUK intends to issue the initial notice of liability for the 2026 to 2027 year. Payment is usually made in quarterly instalments set out in the notice.
• 1 April 2027: large producers report packaging data for July to December 2026. Small producers report data for the whole of 2026 and register for 2027.
• 2027 scheme year: household packaging supplied in 2027 is assessed under RAM 2027.
• 1 October 2027: large producers report packaging data for January to June 2027.

Check the government’s EPR guidance for the dates that apply to you, as deadlines and fees can change.

Who reports the packaging when a 3PL packs your orders?

This is one of the most common questions brands ask once they outsource fulfilment, and the answer depends on whose brand is on the packaging.

Under the government’s guidance, a brand owner reports filled branded packaging supplied under its brand, including when another organisation packs the goods for it. Unbranded packaging, such as plain shipping boxes, mailers and void fill, is generally reported by the business that packs or fills it, whether it does so for its own goods or for another organisation.

In practice, that means you and your fulfilment provider need to agree:

• Which packaging carries your brand and is reported by you.
• Which unbranded shipment packaging is added in the warehouse, and who reports it.
• How packaging weights and materials will be recorded for each order or SKU.
• How that data will be shared with you, and when, so you can meet your reporting deadlines.

Make this part of your contract or onboarding, not something you discover a week before a deadline. If you are unsure how the rules apply to your arrangement, check the government guidance on how to collect your packaging data, or ask a compliance scheme.

Practical ways to reduce your EPR costs

Use less packaging

EPR fees are charged by weight. Right-sized boxes and mailers, lighter void fill and removing unnecessary inserts all cut the tonnage you report. They usually cut courier costs too, because smaller parcels fall into cheaper size and dimensional weight bands. Our fulfilment pricing guide shows how packaging and courier costs feed into your total cost per order.

Choose recyclable, single-material formats

Packaging made from one material, such as a plain cardboard box with paper tape and paper fill, is generally easier to recycle than packaging that mixes materials. Before switching formats, check how the new packaging is likely to be rated, since some paper-based formats with plastic coatings are rated red.

Avoid over-specifying

Not every product needs a double-wall box and fill. Match protection to the product. A fulfilment partner that packs thousands of orders a day can tell you where your packaging is more than the product needs, and where cutting back would cause damage.

Keep accurate records

Good data is the foundation of EPR compliance. Record the weight and material of every packaging item you use, by SKU or order type, so your reported figures are accurate and you can see where changes would have the biggest effect.

Review Plastic Packaging Tax at the same time

Plastic Packaging Tax is a separate charge from EPR. It applies to plastic packaging components that contain less than 30% recycled plastic. If you use plastic mailers or bags, check whether the tax applies and whether switching to higher recycled content would remove it.

Our guide to sustainable packaging fulfilment compares the packaging options available through a fulfilment partner, their costs and their trade-offs.

How Ogden Fulfilment helps with packaging

Ogden Fulfilment gained ISO 14001 environmental accreditation in 2020, and reducing waste and material use is part of how our warehouses run. You can read more about our approach on our environment page.

When we pack your orders as part of our 3PL services, we can:

• Pack to your specification using branded or plain packaging, as part of our warehouse packing service.
• Help you right-size packaging for your best-selling SKUs to reduce both material weight and courier costs.
• Agree clearly at onboarding which packaging is branded and which is added in the warehouse.
• Provide the packaging information you need for your own records and reporting.

Frequently asked questions

Does packaging EPR apply to small online businesses?

EPR obligations apply only if your business has an annual turnover of £1 million or more and supplied or imported more than 25 tonnes of packaging in the UK in the previous year. Businesses below either threshold are not obligated producers, but should track their packaging as they grow.

What is shipment packaging under EPR?

Shipment packaging is the packaging used to send goods to consumers, including goods sold online. For ecommerce brands, it covers the outer boxes, mailers and protective materials used to ship orders.

What are red, amber and green packaging ratings?

They are recyclability ratings under PackUK’s Recyclability Assessment Methodology. Green packaging pays a lower fee, amber pays the standard fee and red packaging, which is hard to recycle, pays a higher fee. In 2026 to 2027, red packaging pays 1.2 times the amber fee.

Who reports packaging when a 3PL packs my orders?

Generally, the brand owner reports branded packaging, while unbranded packaging such as plain shipping boxes is reported by the business that packs it. Agree the split clearly with your fulfilment provider and check the government guidance for your situation.

Is Plastic Packaging Tax the same as EPR?

No. Plastic Packaging Tax is a separate tax on plastic packaging components with less than 30% recycled plastic. A business can be affected by both, one or neither.

Talk to us about your packaging

If you want to cut packaging weight, simplify your EPR reporting or move to more recyclable formats without increasing damage rates, speak to our team or call 0330 058 5621.