Five UK-based groups face the same three packaging charges, but each one's own disclosures point to a different lever

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).

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, 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). 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.

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.

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

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.

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). 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 sets the UK tax against Spain’s and the Isle of Man’s.

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.

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.