# Five UK-based groups face the same three packaging charges, but each one’s own disclosures point to a different lever > In the UK a tonne of plastic packaging can carry up to three charges: Plastic Packaging Tax at GBP 228.82 a tonne below 30% recycled plastic, a PackUK disposal fee of GBP 415 to GBP 545 a tonne at year 2 illustrative rates, and, from October 2027, a drinks deposit fee; which of them bites hardest differs for Tesco, ALDI UK, Reckitt, Haleon and GSK. Publisher: Strategic Packaging Insights Published: 2026-10-29 Last updated: 2026-10-29 Page: https://www.strategicpackaginginsights.com/insights/uk-groups-epr-plastic-packaging-tax-tesco-reckitt-gsk-haleon-aldi/ **In the UK a tonne of plastic packaging can carry up to three charges: Plastic Packaging Tax at GBP 228.82 a tonne below 30% recycled plastic, a PackUK disposal fee of GBP 415 to GBP 545 a tonne at year 2 illustrative rates, and, from October 2027, a drinks deposit fee; which of them bites hardest differs for Tesco, ALDI UK, Reckitt, Haleon and GSK.** Strategic Packaging Insights (SPI) read what each of the five says about UK packaging in its latest reports and priced its typical packs through the GOV.UK tables, in sterling only. A retailer's own-brand film, a household cleaner bottle at 12% recycled content and a licensed medicine blister land in different rows of the same rulebook. ## Executive summary The UK is the one market where all five of these groups are headquartered or run their whole business, and it now charges for packaging in three separate ways. HMRC's Plastic Packaging Tax ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)) has been GBP 228.82 a tonne since 1 April 2026 on any plastic component with under 30% recycled plastic (GOV.UK, updated 12 February 2026). PackUK's disposal fees under SI 2024/1332 ([PR-GB-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-002/)) charge large producers for household packaging, and 2026 to 2027 is the first year in which the fee depends on a red, amber or green recyclability rating. Drinks deposits start on 1 October 2027. The charges stack but test different things. The tax looks at recycled content at manufacture or import; the disposal fee looks at recyclability at supply. So a plastic tonne with under 30% recycled content and a red rating costs GBP 773.82 at year 2 illustrative rates, by SPI's calculation, while a green tonne above the line costs GBP 415 (Exhibit 1). What the five groups publish decides how far anyone, including their own suppliers, can price that stack. ALDI UK is the only one to publish a UK plastic tonnage: 110,305.88 tonnes of own-label primary plastic in 2023. Tesco publishes UK recyclability (99%, of which 87% kerbside) and names the EPR levy as a cost and a year-end payable, without an amount. Reckitt gives a global 12% recycled content figure; Haleon a global 80% recycle-ready figure; GSK no plastic packaging metric at all (Exhibit 4). SPI groups the five into four UK positions (Exhibit 5). The retailers carry the producer obligation for own brand across thousands of lines, so RAM ratings and supplier specifications are their lever. Reckitt's average sits well under the tax line, so recycled content is its first lever. Haleon's portfolio splits between taxed consumer packs and medicine packs the tax exempts, and GSK's prescription packs are mostly outside the tax, leaving the disposal fee's household test as the question. Leaders should do three things before the year 2 notice of liability, which PackUK intends to issue by the end of November 2026: price red tonnes at the year 3 factor of 1.6, list every component that relies on pre-consumer scrap before it stops counting on 1 April 2027, and ask suppliers for component-level recycled content rather than group averages. ## Key findings 1. Plastic Packaging Tax rose 2.3% to GBP 228.82 a tonne on 1 April 2026 and is 14.4% above its GBP 200 starting rate of April 2022; GOV.UK listed no 2027 to 2028 rate on 29 October 2026. 2. **SPI calculation:** at year 2 illustrative rates, a red plastic tonne with under 30% recycled content costs GBP 773.82 in tax and fee, 86.5% more than a green tonne above the line at GBP 415. 3. ALDI UK reports 124,940.15 tonnes of plastic packaging for 2023, of which 110,305.88 tonnes is own-label primary; **SPI calculation:** priced at the year 2 illustrative plastic rates, that own-label tonnage would carry GBP 45.8 million all green to GBP 60.1 million all red, before any drinks-container exclusion. 4. Tesco's Annual Report 2026 names the new EPR levy as part of cost inflation and as a payable in its GBP 385 million net working capital inflow, and gives no separate amount. 5. Reckitt's plastic packaging averaged 12% recycled content in 2024, 18 points below the tax line, and 81% was recyclable or reusable (Sustainability Report 2025). 6. Plastic packaging for the immediate packaging of licensed human medicines is not subject to the tax, yet still counts toward the 10 tonne registration threshold (GOV.UK, HMRC exemption guidance). 7. **SPI calculation:** if year 2 amber fees held, 1,000 tonnes of red film would cost GBP 545,000 in 2026 to 2027, GBP 728,000 in 2027 to 2028 and GBP 910,000 in 2028 to 2029, plus GBP 228,820 of tax if below the line. ## Three charges, three tests UK packaging policy reaches a pack through three money flows run by three different bodies (Exhibit 2). Each has its own payer, its own test and its own calendar, and a business can be the payer for one and not another. The tax is a cliff, not a slope. Section 47 of the Finance Act 2021 makes a finished component chargeable when recycled plastic is less than 30% of its plastic, and then the whole weight pays. A component at 29% recycled content pays the same per tonne as one at 0% (SPI Regulation Tracker, [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)). The disposal fee is a slope with three steps. PackUK sets one base fee per material and, from 2026 to 2027, multiplies the amber fee by 1.2 for red, rising to 1.6 in 2027 to 2028 and 2.0 in 2028 to 2029; the extra money is returned as one equal percentage discount on green tonnes (PackUK modulation statement, dated 28 June 2025). The mechanics are set out in full in the [SPI Ledger piece on RAM ratings](https://www.strategicpackaginginsights.com/insights/uk-epr-year-2-ram-ratings-packaging-bill/), and this article does not repeat them. The deposit fee replaces part of the disposal fee for drinks. PackUK's year 2 illustrative method leaves single-use PET, aluminium and steel drinks containers between 150 ml and 3 litres out of the tonnages of their material categories, because they are in scope of the deposit schemes (GOV.UK, updated 19 December 2025). Exchange for Change's newsletter of 30 September 2026 says producer fees for all drinks containers will be 0p for the first 15 months from the October 2027 launch. The payers differ even inside one supply chain. Tesco and ALDI UK are the producer for their own-label packaging under SI 2024/1332, but the tax on a UK-made tray falls on the converter that makes it, which may pass it on under section 70 of the Finance Act 2021, the clause that lets a supplier adjust prices under an existing contract when the tax applies (SPI Regulation Tracker, [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)). On imported own-label goods the retailer or its importer is the taxpayer. ## The fee table these packs are priced on Exhibit 3 sets the year 1 base fees against PackUK's year 2 illustrative fees for the materials the five groups report using. Year 1 charged one flat rate per material; year 2 splits each into three. Two features matter for the five groups. First, plastic has the widest absolute gap between red and green of the common materials, GBP 130 a tonne, so the RAM rating of plastic lines moves a bill more than the rating of board or glass. Second, PackUK warned that "Current data suggests that materials rated green may receive a discount of around 9%", and that discount depends on how much red tonnage the whole market reports, not on any one producer (see Industry reaction). The year 2 figures are still illustrative. PackUK's operational plan, updated on 10 August 2026, says year 2 disposal fees will be calculated in November 2026 and that it intends to issue the initial notice of liability for 2026 to 2027 by the end of November, with total forecast fee recovery of about GBP 1.558 billion. The GOV.UK collection page for packaging EPR, last updated on 8 October 2026, listed no confirmed year 2 fee table on 29 October 2026. ## What each group says about UK packaging The five groups report packaging in five different ways, and only some of it is UK-specific (Exhibit 4). That matters because both UK charges are calculated per component and per material, while most corporate packaging metrics are portfolio averages. SPI analysis The gaps are not equal in cost. A missing UK tonnage stops an outsider from sizing the bill, but a missing component-level recycled content figure is what stops a group from knowing whether it pays the tax at all. On the disclosures in Exhibit 4, Tesco and Haleon can say most about their RAM position, ALDI UK about its scale, and Reckitt about its distance from the tax line. ## Four UK positions Putting the producer role together with the lever each group's own data points to gives four positions (Exhibit 5). The test is simple: who is the producer for the pack under SI 2024/1332, and which of the two charges its published numbers say is the larger risk. **Position A, own-label portfolio manager.** For a retailer the disposal fee is a portfolio problem. Tesco's own list of red, amber and green materials, used since 2019 with red materials prohibited, predates PackUK's ratings, which are set under RAM rather than by retailers (SPI Packaging Buyers Database, Tesco profile). ALDI UK says 90% of its plastic footprint comes from own-label primary packaging, so it carries most of the producer obligation for what it sells. **Position B, branded volume below the line.** A group average 18 points under 30% does not mean every component pays, but it means the typical one is far from passing. For Reckitt the tax, not the rating, is the first number to model. **Position C, split portfolio.** HMRC says plastic packaging made or imported for the immediate packaging of licensed human medicinal products is not subject to the tax, and defines immediate packaging as the container in direct contact with the product when it is produced (GOV.UK exemption guidance, updated 12 October 2022). A consumer health group therefore needs a pack-by-pack view of which products are licensed medicines. **Position D, prescription medicines.** Most of GSK's immediate packs sit inside that exemption, and the disposal fee applies only to household packaging. How medicines packs are classified for EPR is covered in the [SPI Ledger piece on pharma packaging](https://www.strategicpackaginginsights.com/insights/pharma-packaging-epr-ppwr-gsk-pfizer-sanofi-haleon/). ## Worked examples: one pack per group Exhibit 6 prices one pack type that each group names in its own reports, per tonne, at the 2026 to 2027 tax rate and year 2 illustrative fees. The RAM ratings and, where unreported, the recycled content shares are SPI assumptions, stated in the table. **Tesco film.** RAM 2027 says flexible packaging items cannot currently be rated green, so the best a film line can reach from 2027 data is amber (GOV.UK, RAM 2027 materials assessment guidance, updated 20 August 2026). At amber and above the tax line, the same tonne would cost GBP 455. **ALDI UK bottles.** ALDI UK said in April 2024 that own-label soft drinks and water bottles in England and Wales were moving to 100% recycled PET, excluding cap and label, saving about 10,000 tonnes of virgin plastic a year. Such a bottle passes the tax test on the bottle body, and PackUK's illustrative year 2 method keeps in-scope drinks containers out of the tonnage. SPI reads that as no year 2 disposal fee on the bottle body; the notice of liability will show whether that holds. Caps and labels are separate components with their own tests. **Reckitt bottle.** At 12% recycled content the tax is GBP 228.82 a tonne whatever the rating. Moving the same bottle to 30% post-consumer content would cut GBP 228.82; moving it from amber to green would cut GBP 40 in year 2. **SPI analysis:** for a bottle below the line, recycled content is worth 5.7 times as much per tonne as the year 2 rating step. **Haleon tube.** RAM 2027 lists some toothpaste tube designs, including mono-material laminates, among its rigid plastic examples, so a tube is assessed under rigid rules rather than the flexible rules that cap film at amber. Haleon says WRAP designates its recycle-ready tube recyclable in the UK. Haleon does not publish the tube's recycled content, so the tax line in Exhibit 6 is the taxed case. **Medicine packs.** The exemption removes the tax but not the disposal fee. A red-rated blister or sachet supplied to households pays the red fee like any other plastic, which is why the household test, not the tax, is the cost question for prescription packs. ## In practice: the five groups In practice: Tesco. Tesco's UK sales were GBP 49,819 million on a 52-week basis in the year to 28 February 2026 (Annual Report 2026). The same report lists the new EPR levy among the cost inflation that sales and savings more than offset, alongside higher National Insurance contributions, and cites a payable relating to the levy as one driver of a GBP 385 million net working capital inflow. Its Sustainability Report 2026 records 99% of UK Own Brand packaging by weight as recyclable and 87% as recyclable at kerbside, and reports packaging data a year in arrears through Valpak (SPI Packaging Buyers Database). Tesco is Deputy Chair of PackUK's Scheme Administrator Steering Group. **SPI calculation:** the 12 points between 99 and 87 are packaging recyclable only through other routes, mainly the soft plastic collection points in large stores. English councils must collect plastic film and bags with plastic recycling from 31 March 2027 (GOV.UK, Simpler Recycling guidance), which changes where that band is collected but not, under RAM 2027, the cap on film at amber. In practice: ALDI UK. ALDI UK's packaging page reports a plastic tonnage of 124,940.15 tonnes for calendar 2023, covering own-label and branded primary, secondary and tertiary plastic sold in stores and online, with 110,305.88 tonnes of own-label primary plastic, and commits to publishing the data annually. **SPI calculation:** 110,305.88 is 88.3% of 124,940.15, slightly below the 90% the page states. No 2024 or 2025 figure was on the page on 29 October 2026, and no outcome for its 2025 targets of 50% recycled content and a 50% plastic cut had been published (SPI Packaging Buyers Database, ALDI UK profile). In practice: Reckitt. Reckitt's Sustainability Report 2025, published in March 2026, reports 2024 data: 81% of plastic packaging recyclable or reusable, 12% recycled content, against 8% in 2023 and a 25% goal for 2025, and plastic at about 34% of its packaging footprint. It says it will not reach the 100% recyclability level set in 2018 and will set refreshed 2030 goals. Its Essential Home business left the group on 31 December 2025 (FY2025 results, via SPI Packaging Buyers Database), so its 2025 UK packaging footprint will not match 2026 tonnage. In practice: Haleon. Haleon, headquartered in Weybridge, names tubes and bottles as its two largest plastic formats and paper-based packaging as about half of its packaging footprint (Health, Inclusivity and Sustainability Report 2025). In the year to 30 June 2025, 80% of its packaging was recycle-ready; it says Theraflu sachets, which need high-barrier materials, have no commercially viable recycle-ready option yet, and that it is exploring blister recycling with CiPPPA. Its Annual Report and Form 20-F 2025, filed on 13 March 2026, says it will revisit its 2030 recyclability goal during 2026. In practice: GSK. GSK, headquartered in London, has no plastic packaging target. Packaging enters a 25% product and packaging environmental impact goal for 2030, measured as carbon, and a 10% supply chain waste cut from a 2022 baseline of 3.8 million tonnes, of which 3% was achieved by 2025, mainly through its aluminium packaging supply chain (Responsible Business 2025). It reports recycled card in packaging and e-leaflets for vaccines (SPI Packaging Buyers Database, GSK profile). ## ALDI UK's footprint at UK rates ALDI UK is the one group of the five whose published tonnage can be run through the GOV.UK tables. Exhibit 7 does so for the own-label primary figure, in sterling, as an order of magnitude and not as ALDI UK's bill. The working is the tonnage times each rate: 110,305.88 x 455 = GBP 50,189,175.40 at amber. The green to red range on the same tonnage is GBP 14,339,764.40. **SPI analysis:** for a retailer of this scale, every percentage point of own-label plastic moved from red to green is worth about GBP 143,398 a year at year 2 illustrative rates, by SPI's calculation (1% of 110,305.88 tonnes x GBP 130), and more at the later red factors. The tax rows show why ALDI UK's 50% recycled content target matters for its suppliers even though no outcome has been published. If half of the tonnage were in components below 30%, the tax embedded in its supply chain would be about GBP 12.6 million a year at the 2026 to 2027 rate. The 10,000 tonnes of virgin plastic it said the rPET bottle switch would save sit in components that now pass the tax test. ## The film problem for retailers Film is where both retailers' disclosures and the RAM rules meet. Tesco's 12-point gap between recyclable and kerbside-recyclable packaging is mostly soft plastic, and RAM 2027 caps flexible items at amber. Exhibit 8 holds year 2 amber fees steady and applies PackUK's published red factors to 1,000 tonnes of film. By year 4 the red premium on film alone is GBP 455,000 per 1,000 tonnes over amber, by SPI's calculation. Because film cannot reach green, the value of fixing a red film line is the red to amber step, not red to green. That is the opposite of rigid packs, where green is open. SPI analysis For Tesco and ALDI UK the cheapest film line is an amber film above 30% recycled content, and the most expensive is a red film below it. ALDI UK's crisp packs with a minimum of 35% recycled content (SPI Packaging Buyers Database) are an example of the first half of that combination; whether such packs rate amber is not published. ## Scenarios: a 1,000 tonne bottle line Exhibit 9 runs four cases for 1,000 tonnes of rigid household bottles, the format Reckitt names for Harpic, Dettol and Lysol and Haleon for Centrum and mouthwash. Each case is in sterling and uses only published rates and factors. Moving from the base to the low case saves GBP 268,820 a year, of which GBP 228,820, or 85.1%, is the tax, by SPI's calculation. In the stress case the disposal fee becomes the larger part of the gap: red at 1.6 adds GBP 273,000 over amber. The 1 April 2027 change can move a bottle across the cliff in the wrong direction. HMRC confirmed on 26 November 2025 that pre-consumer plastic, scrap from manufacturing, stops counting as recycled from that date, while chemically recycled plastic allocated through a certified mass balance process can start counting (SPI Regulation Tracker, [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)). A bottle at 30% recycled content that relies on 5 points of pre-consumer scrap would be at 25% and taxed in full. HMRC's draft certification regulations were published on 6 October 2026, with comments due by 21 December 2026. ## The tax rate path The tax rises each April with inflation. Exhibit 10 shows the five rates GOV.UK lists since the tax began. **SPI calculation:** the step from GBP 223.69 to GBP 228.82 is 2.3%, smaller than the 7.6% rise in the plastic disposal fee from GBP 423 in year 1 to GBP 455 amber in year 2. The two charges are now moving at different speeds, and from 2027 to 2028 the red factor will move the fee faster still. The [plastic packaging taxes piece](https://www.strategicpackaginginsights.com/insights/plastic-packaging-taxes-2026/) sets the UK tax against Spain's and the Isle of Man's. ## Industry reaction > "The net working capital inflow of £385m is mainly driven by our solid sales performance, which led to higher trade payables, strong working capital management, and a payable relating to the new EPR levy." ***Tesco PLC** , retailer, [Annual Report and Financial Statements 2026](https://www.tescoplc.com/media/gmylxjfw/tesco_ar26_interactive.pdf), statements dated 15 April 2026* The sentence is the clearest statement among the five groups that the UK levy has reached the accounts, though the report does not give the amount of the payable. Reckitt's [Sustainability Report 2025](https://eu-assets.contentstack.com/v3/assets/blt93c8bc7a598af9f0/blt8d0848c0b02e7e52/69cd46220c530c95012e3f8d/Reckitt_Sustainability_Report_2025.pdf), published in March 2026, says packaging costs and regulations keep rising through EPR schemes and, most notably, the forthcoming EU Packaging and Packaging Waste Regulation, and that it is first strengthening its data capabilities so local teams can meet higher reporting requirements. > "Current data suggests that materials rated green may receive a discount of around 9%." ***PackUK** , UK scheme administrator, [Year 2 illustrative waste disposal fees](https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging), 16 December 2025, updated 19 December 2025* The discount is funded by red tonnage across the market, so a retailer's green lines get cheaper when other producers report more red. ## What suppliers to the five should expect The four positions in Exhibit 5 translate into different asks of packaging suppliers, and the published data already hints at which ones. **Suppliers to Tesco and ALDI UK.** Both retailers are the producer for their own-label packaging, so they need line-level data to check PackUK's notice: material, weight, household or non-household, and the RAM rating under RAM 1.1 for 2026 supply and RAM 2027 from January 2027. Tesco's 30% recycled content ask for rigid plastic matches the tax line exactly, and ALDI UK's 50% target sits above it. **SPI analysis:** a converter that can show post-consumer content per component, separate from pre-consumer scrap, answers both retailers' questions and its own tax return with one data set. **Suppliers to Reckitt.** At a 12% average, the cost gap in Exhibit 9 is largest where Reckitt's bottles are below the line. Suppliers that can lift a UK bottle to 30% post-consumer content remove GBP 228.82 a tonne of tax at the 2026 to 2027 rate, worth more than any year 2 rating step on plastic. Reckitt's refreshed 2030 goals, which it said in March 2026 it would set, will show whether recycled content or virgin plastic reduction leads its next round of specifications. **Suppliers to Haleon and GSK.** For medicine packs, the useful evidence is the licence status of the product inside, because it decides whether the tax applies to the immediate pack. Cartons, leaflets and outer packs are not immediate packaging and fall under the normal rules. GSK's only published packaging lever is carbon, so a supplier's carbon data per pack may matter as much to GSK as its recycled content. Haleon's tube work shows the other route: a format change that moves a pack into the rigid plastic rules, where green is possible. SPI analysis Across all five, the scarce input is not material but data. Each UK charge is computed per component, while four of the five groups publish only portfolio figures, so the supplier that can provide component data is the one that lets its customer forecast the bill. ## The limits of this view **Tonnage.** Four of the five groups publish no UK packaging tonnage, so Exhibits 6, 8 and 9 are per tonne or per 1,000 tonnes and are not company bills. ALDI UK's figure is for 2023. **Ratings.** None of the five publishes RAM ratings by line, so every rating in this piece is an SPI assumption. RAM 2027 applies from the 2027 reporting year; 2026 data is rated under RAM version 1.1. **Who pays the tax.** The tax falls on the UK manufacturer or importer of each component. For UK-made own-label packaging that is usually a converter, and the cost reaches the retailer through price. SPI has not seen any of the five groups' supplier contracts. **Medicines.** Which Haleon products hold UK medicine licences, and so which of its immediate packs are exempt, is not yet confirmed by SPI. The exempt packaging still counts toward the 10 tonne registration test. ## What leaders should do now 1. **Finance leads at UK retailers and brand owners, by 30 November 2026:** hold a budget line for the year 2 notice of liability, and reconcile it to the 2025 data submitted before the 1 September 2026 resubmission cut-off. 2. **Packaging teams, by 31 December 2026:** list every red line and cost it at the 1.6 factor for 2027 to 2028; for film, treat amber as the target, since RAM 2027 does not allow green. 3. **Procurement at Tesco, ALDI UK and their suppliers, by 31 January 2027:** ask converters for component-level recycled content, split into post-consumer and pre-consumer, and for the tax line they pass on under section 70. 4. **Brand owners with averages below 30%, by 1 April 2027:** identify components that pass the tax test only through pre-consumer scrap and source post-consumer or certified chemically recycled content before that credit ends. 5. **Regulatory teams at health groups, by the first 2027 tax return:** map each pack to its medicine licence status so exempt immediate packs and taxed consumer packs are separated, while keeping both in the 10 tonne count. 6. **Drinks category teams at retailers, by 1 October 2027:** confirm which own-label bottles leave the disposal fee tonnage and register with Exchange for Change for the deposit, whose producer fee is 0p until December 2028. 7. **Boards, at the next budget review:** ask for the UK packaging cost split into tax, disposal fee and deposit, in sterling, rather than one EPR total. ## Questions for your board - Which of our UK components are below 30% recycled plastic today, and which will fall below it on 1 April 2027 when pre-consumer scrap stops counting? - How many tonnes of our UK household packaging are rated red, and what do they cost at the factors of 1.6 and 2.0? - Do we publish a UK packaging tonnage, and if not, how would we size our own bill for investors? - Who pays the tax on our packaging: us as importer, or our converters through price? - Which of our packs leave the disposal fee for the drinks deposit in October 2027? - For health products, which packs are exempt as immediate packaging of licensed medicines? ## What to watch - **30 Nov 2026:** PackUK aims to issue the year 2 notice of liability, replacing the illustrative rates used here ([PR-GB-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-002/)). - **21 Dec 2026:** comments close on HMRC's draft Plastic Packaging Tax (Chemical Recycling Certification Schemes) Regulations 2027 ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)). - **31 Mar 2027:** English councils must collect plastic film and bags with plastic recycling under Simpler Recycling. - **1 Apr 2027:** pre-consumer plastic stops counting for the tax, the red factor rises to 1.6, and large producers file July to December 2026 data. - **May 2027:** Exchange for Change reviews and reconfirms its producer fees for 2029 to 2032 ([PR-GB-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-004/)). - **1 Oct 2027:** drinks deposits start in England, Northern Ireland and Scotland ([PR-GB-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-004/), [PR-GB-005](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-005/)). ## Methodology - **Data used:** SPI Packaging Buyers Database profiles for Tesco, ALDI UK, Reckitt, GSK and Haleon (data as of 14 October 2026), re-read against the companies' own pages and reports on 29 October 2026; SPI Regulation Tracker rules [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/) to [PR-GB-005](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-005/); the SPI fee-market note for the United Kingdom; GOV.UK and legislation.gov.uk pages listed in Sources. - **Rates:** tax at GBP 228.82 per tonne from 1 April 2026; disposal fees at PackUK's year 2 illustrative rates (19 December 2025) and year 1 base fees (27 June 2025); red factors 1.2, 1.6 and 2.0 from the modulation statement. - **Counting rules:** sterling only, no currency conversion; per tonne figures are tax plus disposal fee for household packaging of a large producer; administration fees, registration fees and recycling evidence costs are excluded. - **Assumptions:** RAM ratings, recycled content where not published, and the shares in Exhibit 7 are SPI assumptions; later fee years hold year 2 amber fees and the 2026 to 2027 tax rate. - **Cut-off:** 29 October 2026. - **Limitations:** illustrative fees may change; the five groups do not publish line-level ratings; the figures are not a liability or an invoice. Confirm obligations with HMRC, PackUK or your compliance scheme, and check with counsel where it applies. ## Sources 1. GOV.UK (HMRC), Plastic Packaging Tax: check if you need to register (rates; updated 12 February 2026), [https://www.gov.uk/guidance/check-if-you-need-to-register-for-plastic-packaging-tax](https://www.gov.uk/guidance/check-if-you-need-to-register-for-plastic-packaging-tax), consulted 2026-10-29. 2. GOV.UK (HMRC), Check which plastic packaging is exempt from Plastic Packaging Tax (updated 12 October 2022), [https://www.gov.uk/guidance/check-which-plastic-packaging-is-exempt-from-plastic-packaging-tax](https://www.gov.uk/guidance/check-which-plastic-packaging-is-exempt-from-plastic-packaging-tax), consulted 2026-10-29. 3. legislation.gov.uk, Finance Act 2021, Part 2 (Plastic packaging tax), [https://www.legislation.gov.uk/ukpga/2021/26/part/2](https://www.legislation.gov.uk/ukpga/2021/26/part/2), consulted 2026-10-14. 4. GOV.UK (HMRC), Plastic Packaging Tax: mass balance approach and removal of pre-consumer plastic (26 November 2025), [https://www.gov.uk/government/publications/plastic-packaging-tax-mass-balance-approach-and-removal-of-pre-consumer-plastic/plastic-packaging-tax-mass-balance-approach-and-removal-of-pre-consumer-plastic](https://www.gov.uk/government/publications/plastic-packaging-tax-mass-balance-approach-and-removal-of-pre-consumer-plastic/plastic-packaging-tax-mass-balance-approach-and-removal-of-pre-consumer-plastic), consulted 2026-10-14. 5. GOV.UK (HMRC), Draft legislation: Plastic packaging tax, chemical recycling and adoption of a mass balance approach (6 October 2026), [https://www.gov.uk/government/consultations/draft-legislation-plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach](https://www.gov.uk/government/consultations/draft-legislation-plastic-packaging-tax-chemical-recycling-and-adoption-of-a-mass-balance-approach), consulted 2026-10-14. 6. GOV.UK (PackUK), Year 2 illustrative waste disposal fees: extended producer responsibility for packaging (16 December 2025, updated 19 December 2025), [https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging](https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging), consulted 2026-10-29. 7. GOV.UK, Extended producer responsibility for packaging: 2025 base fees (27 June 2025, updated 30 June 2025), [https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-2025-base-fees/extended-producer-responsibility-for-packaging-2025-base-fees](https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-2025-base-fees/extended-producer-responsibility-for-packaging-2025-base-fees), consulted 2026-10-29. 8. GOV.UK (PackUK), Producer disposal fees modulation statement (dated 28 June 2025, published 17 February 2026), [https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement](https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement), consulted 2026-10-29. 9. GOV.UK (PackUK), PackUK operational plan: 2026 to 2027 (updated 10 August 2026), [https://www.gov.uk/government/publications/packuk-operational-plan/packuk-operational-plan-2026-to-2027](https://www.gov.uk/government/publications/packuk-operational-plan/packuk-operational-plan-2026-to-2027), consulted 2026-10-29. 10. GOV.UK (PackUK), RAM 2027 materials assessment guidance (1 July 2026, updated 20 August 2026), [https://www.gov.uk/government/publications/assess-packaging-recyclability-recyclability-assessment-methodology-ram-2027/ram-2027-materials-assessment-guidance](https://www.gov.uk/government/publications/assess-packaging-recyclability-recyclability-assessment-methodology-ram-2027/ram-2027-materials-assessment-guidance), consulted 2026-10-29. 11. GOV.UK, Extended producer responsibility for packaging, collection page (updated 8 October 2026), [https://www.gov.uk/government/collections/extended-producer-responsibility-for-packaging](https://www.gov.uk/government/collections/extended-producer-responsibility-for-packaging), consulted 2026-10-29. 12. legislation.gov.uk, SI 2024/1332, regulations 24 and 60, [https://www.legislation.gov.uk/uksi/2024/1332/regulation/60/made](https://www.legislation.gov.uk/uksi/2024/1332/regulation/60/made), consulted 2026-10-14. 13. GOV.UK (Defra), Simpler Recycling: household recycling in England, [https://www.gov.uk/guidance/simpler-recycling-household-recycling-in-england](https://www.gov.uk/guidance/simpler-recycling-household-recycling-in-england), consulted 2026-10-29. 14. Exchange for Change, Newsletter 15 (30 September 2026), [https://exchangeforchange.co.uk/news/exchange-for-change-newsletter-15-september-2026/](https://exchangeforchange.co.uk/news/exchange-for-change-newsletter-15-september-2026/), consulted 2026-10-29. 15. Tesco PLC, Annual Report and Financial Statements 2026 (statements dated 15 April 2026), [https://www.tescoplc.com/media/gmylxjfw/tesco_ar26_interactive.pdf](https://www.tescoplc.com/media/gmylxjfw/tesco_ar26_interactive.pdf), consulted 2026-10-29. 16. Tesco PLC, Sustainability Report 2026, [https://www.tescoplc.com/media/yjmlhji0/tesco-sustainability-report-2026.pdf](https://www.tescoplc.com/media/yjmlhji0/tesco-sustainability-report-2026.pdf), consulted 2026-10-29. 17. ALDI UK, Product packaging and waste, [https://www.aldi.co.uk/corporate/corporate-responsibility/greener/product-packaging-and-waste](https://www.aldi.co.uk/corporate/corporate-responsibility/greener/product-packaging-and-waste), consulted 2026-10-29. 18. ALDI UK, Aldi moves to 100% recycled plastic on soft drink and water bottles in UK supermarket first (25 April 2024), [https://www.aldipresscentre.co.uk/business-news/aldi-moves-to-100-recycled-plastic-on-soft-drink-and-water-bottles-in-uk-supermarket-first/](https://www.aldipresscentre.co.uk/business-news/aldi-moves-to-100-recycled-plastic-on-soft-drink-and-water-bottles-in-uk-supermarket-first/), consulted 2026-10-13. 19. Reckitt, Sustainability Report 2025 (March 2026), [https://eu-assets.contentstack.com/v3/assets/blt93c8bc7a598af9f0/blt8d0848c0b02e7e52/69cd46220c530c95012e3f8d/Reckitt_Sustainability_Report_2025.pdf](https://eu-assets.contentstack.com/v3/assets/blt93c8bc7a598af9f0/blt8d0848c0b02e7e52/69cd46220c530c95012e3f8d/Reckitt_Sustainability_Report_2025.pdf), consulted 2026-10-29. 20. Haleon, Health, Inclusivity and Sustainability Report 2025, [https://www.haleon.com/content/dam/haleon/corporate/documents/investors/oar-2025/health-inclusivity-and-sustainability-report-2025-accessible.pdf](https://www.haleon.com/content/dam/haleon/corporate/documents/investors/oar-2025/health-inclusivity-and-sustainability-report-2025-accessible.pdf), consulted 2026-10-13. 21. Haleon plc, Annual Report and Form 20-F 2025 (13 March 2026), [https://www.sec.gov/Archives/edgar/data/1900304/000110465926027443/hln-20251231x20f.htm](https://www.sec.gov/Archives/edgar/data/1900304/000110465926027443/hln-20251231x20f.htm), consulted 2026-10-29. 22. GSK, Responsible Business 2025, [https://www.gsk.com/media/okghs41i/responsible-business-2025.pdf](https://www.gsk.com/media/okghs41i/responsible-business-2025.pdf), consulted 2026-10-13. 23. SPI Packaging Buyers Database, Tesco, ALDI UK, Reckitt, GSK and Haleon profiles (data as of 14 October 2026), /data/packaging-buyers-database/, consulted 2026-10-29. 24. SPI Regulation Tracker, United Kingdom, rules PR-GB-001 to PR-GB-005, and SPI fee-market note for the United Kingdom (data as of 14 October 2026), /data/packaging-regulation-tracker/united-kingdom/, consulted 2026-10-29.