PackUK sets November for its £1.558 billion year 2 bill, with one notice and no general recalculation

How the year 2 bill is built

PackUK is the scheme administrator for UK packaging extended producer responsibility (EPR), tracked as PR-GB-002, under which large producers pay councils’ costs of managing household packaging waste. Its operational plan sets the 2026 to 2027 cost base at £1.169 billion for England, £158 million for Scotland, £91 million for Wales and £52 million for Northern Ireland, a total of £1.47 billion¹.

On top of that sit £28 million of administration fees, £0.4 million of public information costs and a £60 million impairment, an allowance for fees PackUK expects not to collect. The plan’s total forecast fee recovery is £1.558 billion, which its executive summary rounds to about £1.56 billion. By SPI’s calculation, impairment equals 4.1% of disposal costs, close to the 4% impairment charge the plan says was built into year 1 invoices.

The disposal cost is shared across producers by material and tonnage. Year 2 adds modulation, tracked as PR-GB-003: each tonne is rated red, amber or green under the recyclability assessment methodology (RAM). PackUK’s modulation statement treats amber as the base fee and multiplies it by 1.2 for red in 2026 to 2027, 1.6 in 2027 to 2028 and 2.0 in 2028 to 2029⁶.

The extra money from red tonnage is not kept. It funds an equal percentage discount on every green tonne across all materials, so modulation is designed to leave total disposal fees unchanged. The statement says final modulated fees can only be set once a reporting year’s data is complete, which is why the November calculation matters.

SPI calculation (year 2 against 2025 to 2026): the £1.558 billion forecast is £98 million (6.7%) above the £1.46 billion PackUK invoiced for 2025 to 2026, and £35 million (2.3%) above the £1.523 billion it said that year required. Council disposal costs rise by £30 million (2.1%), from £1.44 billion to £1.47 billion.

“PackUK will only issue a single notice of liability for year 2 of EPR for packaging.” PackUK operational plan 2026 to 2027, updated 10 August 2026

What changed since the plan was first published

27 February: a plan with two passes. PackUK first published its 2026 to 2027 operational plan on 27 February 2026, the publication page’s change notes show². ERP UK, a compliance scheme, said in its 13 March summary that the first version planned initial notices by July 2026, a formal recalculation by November 2026 and a year-end calculation in late March 2027. ERP UK also reported two proposed data cut-offs, 1 May and 1 October 2026.

1 April: the full year of 2025 data. Large producers had to report July to December 2025 packaging data by 1 April 2026, under GOV.UK’s reporting guidance, updated on 19 August 2026⁹. That return completed the 2025 tonnage on which year 2 fees are charged. The operational plan says that where a producer left RAM ratings out of its first-half data, PackUK applies the material-level ratios from its second-half data to the first-half tonnage.

5 May: the cut-off moves later. A change note of 5 May 2026 moved the date for accepting recalculations from 1 October 2026 to 1 November 2026. At that point the plan still allowed for notices to be recalculated after new data arrived.

6 July: a single deadline. PackUK’s news story of 6 July set 1 September 2026 as the last date for corrections to 2025 data, a five-month window from the 1 April reporting deadline. It said PackUK would issue notices of liability later in the calendar year and that producers would again have 50 calendar days to pay³.

10 August: one notice, no general rerun. The plan was updated on 10 August to say PackUK will only accept recalculations for resubmissions made by 1 September. Its current text says fees are calculated in November 2026, the initial notice follows by the end of that month, and any change to an individual liability follows only a successful appeal.

June 2026: a fee table that did not arrive. The December 2025 illustrative fee page said PackUK expected to publish confirmed 2026 to 2027 fees in June 2026, once the full year of data was in. No such table is on GOV.UK. ERP UK said in July that PackUK will not update the indicative base fees before the notice, which is intended to confirm the figures¹³.

1 and 8 October: registration and guidance. Large producers had to register for 2026 to 2027, pay registration fees and report January to June 2026 data by 1 October 2026. GOV.UK’s EPR for packaging collection page was last updated on 8 October, adding guidance on issuing recycling notes; it lists the 2025 base fees and no confirmed year 2 fee document⁸.

“There is no plan for a producer-wide recalculation, and any recalculation of individual liabilities would only occur following a successful appeal of the initial notice of liability.” PackUK operational plan 2026 to 2027, updated 10 August 2026

What a year 2 notice of liability contains

A notice of liability is the bill. GOV.UK’s notice of liability guidance, published on 23 March 2026, says it should be treated as the producer’s invoice, though it is not a commercial invoice⁴. It sets out disposal fees by weight and packaging type, including any offset and modulation, plus public information, administration and impairment charges.

Each notice carries instalment dates and amounts, late-payment interest terms, a recalculation statement, complaint and appeal routes and a unique virtual bank account number for payment. Payment is usually in quarterly instalments, by quarterly direct debit set up through a link on the notice, bank transfer, card or standing order. Producers who do not use direct debit must contact PackUK’s customer support to set up a payment plan.

The guidance sets out what follows non-payment. PackUK can charge interest and take enforcement action, including a variable monetary penalty, if an instalment is not paid within 50 days of its due date. The guidance links the penalty to 20% of unpaid disposal and administration fees or a share of turnover, 5% for a single registration and 2% for a group; it begins with a notice of intent and 28 days to respond.

Disputes start with PackUK. A producer must raise a complaint through the report packaging data portal before appealing, and a tribunal appeal must follow within 2 months of the complaint being resolved, the guidance says. PackUK’s appeals guidance, updated on 23 September 2025, lists a notice of liability for a disposal or administration fee as appealable on two grounds: the producer is not liable, or the amount was miscalculated¹¹.

Recalculation still exists for individual cases. The guidance says producers must keep paying the current notice; if a liability falls, PackUK issues a revised notice and the payment dates stay the same, and if it rises, a second notice covers the extra amount. PackUK can recalculate up to 4 years after the assessment year ends, or 10 years where the producer’s action or inaction delayed the information.

SPI calculation (payment clock): a notice issued on 30 November 2026 with 50 calendar days to pay runs to 19 January 2027. That matches ERP UK’s estimate of mid-January for the first quarterly payment, but the actual dates will be those printed on each notice.

PackUK’s own service targets apply to this stage. The operational plan sets a 100% target for issuing notices of liability, collecting producer payments and paying councils within agreed timeframes, and aims to answer 85% of calls within 20 seconds and raise first-contact resolution of payment calls from 80% to 90%.

Who pays most when the notices land

Large producers of household packaging. The notice goes to large producers, for household packaging they placed on the UK market in 2025. GOV.UK’s fees guidance limits fees to household, commonly binned and household glass drinks packaging¹⁰.

Plastic packaging. Plastic carries one of the widest spreads at illustrative year 2 rates: £415 a tonne green, £455 amber and £545 red, against a flat £423 base fee in year 1. By SPI’s calculation, every 1,000 tonnes of red-rated plastic costs £90,000 more than amber and £130,000 more than green at those rates. The rates are illustrative and PackUK said in December 2025 they are likely to change significantly⁵.

Fibre-based composite and wood. Fibre-based composite has the highest illustrative rates, £475 green, £525 amber and £630 red, so its red premium over amber is £105,000 per 1,000 tonnes by SPI’s calculation. Wood’s illustrative red rate of £540 is £90 above amber, the same gap as plastic.

Glass, paper and board. Glass and paper and board carry the lowest illustrative rates, with a red premium of £40 a tonne over amber. Glass’s illustrative amber rate of £205 compares with a year 1 base fee of £192, GOV.UK’s fees page shows.

Producers who corrected data late. Any producer that resubmitted 2025 data after 1 September 2026 will get a notice based on its earlier return, the operational plan says. A correction that would have cut its liability does not reduce the November bill unless an appeal succeeds.

Producers who registered late. The 2025 to 2026 invoices were set below the £1.523 billion required to reflect data from anticipated late registrants, the plan says. ERP UK said in July that late registrants will receive a new notice, with reconciliation later.

Councils in the four nations. England’s councils account for £1.169 billion of year 2 disposal costs, 79.5% of the total by SPI’s calculation. Councils are paid from producer income, and the plan says payments will move to a quarterly cycle, without a 2026 to 2027 schedule.

Named producer exposure is in the SPI Buyers Database, which profiles brand owners and retailers by market and packaging type. SPI has not yet confirmed any company’s own estimate of its year 2 notice.

The data that sets the bill

The year 2 bill rests on 2025 data as it stood on 1 September 2026. The operational plan says that once all data is received, PackUK works with the four environmental regulators, the Environment Agency, Natural Resources Wales, the Scottish Environment Protection Agency (SEPA) and the Northern Ireland Environment Agency (NIEA), as they scrutinise it before it is used in November’s calculation.

England’s regulator set out its approach in advance. The Environment Agency’s monitoring plan for 2026, published on 22 December 2025, gives its monitoring policy and the minimum number of businesses it proposes to monitor under the packaging regulations in England¹². The plan for 2025 to 2026 also says PackUK estimated the number of producers brought into the scheme by regulators in the four nations.

RAM coverage is the weak point. When PackUK published illustrative rates in December 2025, RAM data covered 45% of first-half 2025 tonnage, rated 71% green, 8% amber and 21% red, and the green discount was a provisional figure of about 9%. The final discount depends on the share of tonnage that ends up red across all producers, so one producer’s bill moves with its competitors’ ratings.

The methodology also moves on a separate clock. GOV.UK’s RAM 2027 page, published on 1 July 2026 and updated on 20 August, says RAM 2027 applies to the 2027 reporting year and that producers use RAM version 1.1 for 2026 reporting⁷. The modulation statement says the most recent RAM version is used when each year’s invoices are generated, so the ratings behind future bills can shift each year.

How the four UK nations compare

Year 2 runs one fee calculation and one notice across the UK, but councils, regulators and appeal routes sit with each nation. The operational plan splits the £1.47 billion disposal cost base by nation, and the appeals guidance names a different appeal body for Scotland and for Northern Ireland.

England’s share is the largest by far, and Scotland’s £158 million is larger than Wales and Northern Ireland combined, by SPI’s calculation. Producers pay one notice regardless of where their packaging ends up; the split decides how the money is distributed to councils, not how much each producer pays.

The administration itself is also changing. The operational plan says the producer responsibility organisation application window ran from 3 November to 12 December 2025, with formal appointment aimed for March 2026, and that functions will be delegated gradually over a multi-year period. PackUK remains the body that issues the year 2 notices.

Appeal routes differ. In England and Wales, appeals on a notice go to the First-tier Tribunal (General Regulatory Chamber); in Scotland, to the Scottish Ministers for fee and penalty decisions and the sheriff for council cost decisions; and in Northern Ireland, to the Planning Appeals Commission, PackUK’s appeals guidance says.