Packaging EPR: the 2026 bill for beauty brands

Packaging used to be a cost you paid once, to a supplier. In the UK it is now also a cost you pay annually, to a scheme administrator, priced by material weight and recyclability. For a beauty brand it is rarely the largest line — but it is the only line that changes when you swap a plastic insert for board.

Who is liable

The framework applies to organisations that place packaging on the UK market and meet the turnover and tonnage thresholds. Broadly: larger producers pay disposal fees and report twice yearly; smaller producers above the threshold report but do not pay fees in the same way. A brand importing finished goods is usually the producer for this purpose, even if a factory made the pack.

Two practical consequences. First, a brand selling 5,000 units a year is unlikely to be liable directly, but its retail customers may pass costs down. Second, the data obligation is continuous — tonnage by material, reported on a schedule.

The fees, by material

Illustrative Year 2 figures published by the scheme administrator, per tonne of packaging placed on the market.

Material	Green	Amber (base)	Red
Paper and board	≈£190	£210	≈£250
Glass	≈£186	£205	≈£246
Aluminium	≈£245	£270	≈£325
Plastic	£415	£455	£545
Fibre-based composite	≈£475	£525	≈£630

From 2026–27 the fee is modulated: red-rated packaging pays about 20% more than amber, green-rated about 9% less. The rating comes from the Recyclability Assessment Methodology, which considers whether the format is collected, sortable, recyclable at scale and free of problematic components.

What it means per unit

A 50ml jar with a label and a carton might weigh 65g in total. At 3,000 units that is 0.195 tonnes. If it is plastic-rated at the amber rate, the fee is around £89 for the run — roughly 3p per unit. If the carton is a plastic-laminated composite rated red, the same tonnage could cost around £123, or 4p per unit.

Per unit, it is small. At 30 tonnes a year it is a five-figure line, and the gap between a paper-forward and plastic-heavy strategy is several thousand pounds before any other cost changes.

Four design decisions that move the number

1. Remove the insert. A plastic tray inside a board carton can push the whole unit into a composite band. A moulded pulp or board fitment keeps it in the paper band.
2. Keep the primary pack mono-material. A plastic bottle with a different plastic cap and a foil seal is harder to recycle than an aluminium tin.
3. Question secondary packaging. Cellophane overwrap and unnecessary sleeves add weight, cost and fee without adding shelf presence.
4. Choose coatings deliberately. Aqueous coatings can rate green where a film laminate rates red, with no change to the structure or the print.

EPR is not really a tax on plastic. It is a price signal attached to recyclability, and it is now visible on the specification sheet.

What to do this quarter

Audit secondary packaging by weight. Ask each supplier for the material breakdown of every component, not just the primary pack. Model the fee at your forecast volume. Then decide whether the differentiation you are buying with a bespoke component is worth both the tooling and the recurring fee — sometimes it is, but it should be a decision rather than an accident.

Where this sits in a real project

Pack specification, supplier qualification and EPR modelling sit together in our packaging sourcing work. An illustrative refill scenario shows how a format change moves landed cost and a recyclability claim at the same time. Where the formula is already fixed, the same decisions are made under OEM manufacturing, and the statutory side is covered in UK compliance.

Questions we are asked