Packaging EPR for distributors: who reports what, and where corrugated sits
The thresholds that make a business obligated, which activity catches a distributor, what corrugated costs per tonne, and why that is not the same as per pack.
By Tradepack ·
Extended producer responsibility is the regime most likely to come up in a distributor’s next conversation with a serious customer, and the one most likely to be described incorrectly. It is not the plastic packaging tax, corrugated is not exempt from it, and it does not fall on whoever happens to be holding the packaging.
What follows is a plain summary of the published position as it stood in October 2026. It is general information rather than compliance advice: thresholds and fees are set by government and change, and your own obligation depends on facts about your business that only you have. The source is GOV.UK and PackUK, and your regulator or compliance scheme is who to confirm it with.
Who is obligated
Three things have to be true at once. You are a UK-established business, subsidiary or corporate group; you supplied or imported more than 25 tonnes of packaging in the UK in the previous year; and your annual worldwide turnover was £1 million or more.
Miss either threshold and there is no obligation. Clear both and you are either a small or a large producer:
| Packaging weight | £1m or less turnover | £1m to £2m | More than £2m |
|---|---|---|---|
| Less than 25 tonnes | No obligation | No obligation | No obligation |
| 25 to 50 tonnes | No obligation | Small producer | Small producer |
| More than 50 tonnes | No obligation | Small producer | Large producer |
The difference is substantial. A small producer registers with its environmental regulator, reports packaging data once a year and keeps the data for seven years. A large producer registers annually, reports every six months, acquires recycling notes to meet its recycling obligation, submits a certificate of compliance, pays a waste disposal fee to PackUK for household packaging, and keeps the data for seven years.
Which activity catches a distributor
Being obligated depends on doing a packaging activity. The published list is:
- supplying filled packaging under your own brand
- packing goods or filling packaging
- importing goods in packaging
- supplying unfilled packaging that you manufacture or import
- hiring or loaning out reusable packaging
- owning an online marketplace where packaging is supplied into the UK from outside it
- selling filled packaging to an end user, business or consumer
Read the fourth one carefully, because it is the one distributors assume applies to them. The activity is supplying unfilled packaging that you manufacture or import. A distributor buying UK-made cases and reselling them empty has done neither. The manufacturer is the one who made it.
That is not a general exemption, and it is where the assumption goes wrong in the other direction. Distributors are routinely caught by the other activities on the list: packaging stock imported directly from outside the UK, own-brand ranges, anything packed or filled in house, a marketplace listing, and the transit packaging used to ship orders out. The question is not whether packaging passes through your business. It is which activity you are doing with it.
What the material actually costs
The confirmed base fees are the 2025/26 set, charged per tonne of household packaging:
| Material | 2025/26 base fee |
|---|---|
| Glass | £192 |
| Paper and board | £196 |
| Aluminium | £266 |
| Steel | £259 |
| Wood | £280 |
| Other | £259 |
| Plastic | £423 |
| Fibre-based composite | £461 |
Corrugated sits near the bottom, at less than half the plastic rate. That is the figure everyone quotes, and on its own it is misleading.
The per-tonne trap
Fees are charged by weight, and corrugated is heavier than the plastic it usually replaces.
Work it through on a mailer. A 150 g board mailer at £196 a tonne carries about 2.9p of fee. A 20 g plastic mailer at £423 a tonne carries about 0.8p. The rate per tonne more than halves on the switch, and the fee per pack roughly triples.
This matters because “corrugated is cheaper under EPR” is a sentence distributors are repeating, and a customer who runs the numbers on their own pack will find it is not true for them. The defensible version is narrower and more useful: corrugated is the cheaper material per tonne, it is recyclable in the existing kerbside stream, it avoids the plastic packaging tax entirely, and whether it reduces a given customer’s EPR bill depends on the weight of the pack they end up with.
Which turns the conversation towards the thing that genuinely reduces the fee.
Weight is the lever you control
EPR charges tonnage, so every gram removed is charged at the same rate as every gram kept. Two things move it:
Right-sized blanks. A box cut to the product rather than to the nearest stock size uses less board, and the saving appears in the material cost, the freight and the EPR tonnage at once. This is ordinary CAD work on an existing specification.
Grade against actual load. A great many specifications carry more board than the job needs because nobody has revisited them since the first order. Moving from double wall to a correctly specified single wall, where the load genuinely allows it, takes real weight out. Our piece on what drives the unit price covers the same ground from the cost side.
Modulation starts to bite
From 2026/27, fees are modulated by RAM, the assessment that rates each packaging item red, amber or green for recyclability. Amber pays the base rate, red pays more, green pays less.
The red multiplier is 1.2 times amber in the first year of modulation, rising to 1.6 the year after and 2.0 the year after that. The green discount is funded from the red premium and was estimated at around 9% for the first year, provisional on the mix of ratings actually reported.
Published illustrative figures for paper and board are £190 green, £210 amber and £250 red per tonne. Plastic is £415, £455 and £545 on the same basis.
Two points follow for anyone selling corrugated. First, plain corrugated with water-based inks and no laminate is the straightforward case for a green rating, which is the position our recyclable packaging guide sets out and the reason the laminates and coatings question matters commercially rather than only environmentally. Second, the gap between red and green widens every year, so a specification that is marginal today gets more expensive to keep.
Household and non-household
The waste disposal fee is charged on household packaging. Packaging that does not reach a household is still reported, and still counts towards recycling obligations, but it does not attract the disposal fee in the same way.
For a distributor supplying trade and wholesale customers, that split is worth getting right rather than assuming the worst, and it is exactly the sort of judgement your compliance scheme exists to make.
Where it stands in October 2026
The 2025/26 base fees above are confirmed. The 2026/27 fees are not: the figures published so far are illustrative, and PackUK has said it cannot finalise them until a full year of producer data has been reported and checked by the four regulators. Confirmed rates and the first notices of liability for the year have been expected around November 2026.
So the sensible position with a customer is that the rates are known in shape and not yet in detail, and that the illustrative numbers are the best available guide rather than a quotable price.
What this means for the specification
Nothing about EPR changes how a box is made. It changes which questions are worth asking before a repeat programme is locked: is the blank right-sized, is the grade right for the load, is there a laminate or coating on it that is costing a rating, and is anybody checking the weight.
We publish what we can support on the manufacturing side, including the energy, inks and adhesives behind the packs we make, on responsible manufacturing. For the separate question of the plastic packaging tax and customers switching away from plastic, see plastic packaging tax and corrugated.
Send us a specification to review and we will come back with the board, the blank size and the weight, which is the number the fee is calculated on.
