Defra publishes revised illustrative base fees for packaging EPR

The Department for Environment, Food and Rural Affairs has published revised illustrative base fees for packaging extended producer responsibility.

The announcement follows scathing criticism from the glass industry, with British Glass saying the fees were likely to have a “severe detrimental impact” on the sector.

However, Defra always planned to publish refined figures once more data had been reported and checked by regulators because of “significant limitations” in the data used to create the original fees.

New version of illustrative base fees

Previous version of fees

The table above shows the original illustrative pEPR base fees rates for 2025/26 for all packaging materials except glass.

How were EPR base fees calculated?

Illustrative base fees were calculated by dividing local authority packaging waste management costs (for household packaging waste) by the total amount of household packaging placed on the market.

The following calculation is carried out for each packaging category separately:  

• Numerator: (1) Costs incurred by local authorities managing waste of that packaging category (household packaging waste only) minus revenues from material sales plus (2) Category’s share of other costs, including Scheme Administrator administration and communication costs, and debt provision costs.
• Denominator: Total weight of that packaging category placed on the market (household packaging only).

Defra said it is in the process of calculating local authority costs to manage household packaging waste, which means the range of fees reflects the current range of scenarios being considered for these costs.

The intermediate illustrative base fees correspond to fees based on the central case scenario of local authority disposal costs and are rounded to the nearest £5.

Defra’s new methodology

The first release of illustrative base fees was based on local authority disposal costs estimated by WRAP’s (Waste and Resources Action Programme) local authority disposal cost model, except for glass. 

Defra’s “Local Authority Packaging Cost and Performance” model has been used for all materials in the second release of illustrative base fees.

This model is still undergoing finalisation, Defra said, but will be used to calculate fees that will form the basis for invoicing obligated packaging producers from 2025.

In the first release of illustrative base fees, all materials used estimated tonnages of packaging placed on the market by obligated producers from the “PackFlow Refresh 2023 reports”.

This release uses the most recent data submitted by large organisations into the Report Packaging Data online portal system for the calendar year 2023 (extracted on 9 September 2024).

How were glass fees calculated?

The requirements to report drink containers for the calendar year 2023 only applied to England, Northern Ireland and Wales. These requirements will extend to Scotland for data from 2024 onwards.

As a result, Defra said there is a risk that the 2023 Report Packaging Data underestimates the amount of household glass packaging placed on the market.

To account for this, estimated tonnages placed on the market from Packflow’s 2023 Refresh reports (the same as those used in the first release of illustrative base fees) have been used for glass instead of Report Packaging Data.

OPRL reaction 

Jude Allan, Interim Managing Director of OPRL, said she was encouraged that Defra had highlighted the need for brands to continue to use labelling to help customers recycle in the interim.

Allan described the delay as a “slight set-back”, but commented: “Communicating with customers through on-pack labelling will remain central to the success of pEPR, so it is important to build on the work that OPRL has been doing for 15 years.

“We do not want to lose momentum when it comes to providing clear advice to householders about how to dispose of their packaging.”

“We know that Defra will be exploring ways to introduce a labelling regime that benefits businesses and consumers alike.

“OPRL will be liaising with Defra and will continue to inform our members around the latest developments, as well as continuing and developing our services to our members.”