How to Cut Your EPR Fees by 40%: A Practical Guide

Extended Producer Responsibility fees are no longer a rounding error on the P&L. With fee modulation now live and escalating through 2029, the gap between a well-optimised packaging portfolio and an unoptimised one can easily reach tens of thousands of pounds per year, and for larger producers, hundreds of thousands.

The good news is that most producers have significant room to reduce their EPR fees without compromising product protection, shelf appeal, or supply chain reliability. We have seen businesses cut their projected fees by 30–40% through a combination of targeted material changes, design improvements, and better data management.

This guide walks through seven proven strategies, ordered from highest impact to easiest implementation. Each strategy includes before-and-after cost examples so you can estimate the potential savings for your own portfolio.

The Fee Reduction Framework

Before diving into specific tactics, it helps to understand the three levers that determine your total EPR fee bill:

1. Tonnage: The total weight of packaging you place on the UK market. Less packaging means lower fees, full stop.
2. Material type: Different materials carry different base rates per tonne. Plastic is the most expensive; glass and wood are among the cheapest.
3. RAM rating: Under fee modulation, Green-rated packaging costs less than Amber, which costs less than Red. This lever becomes increasingly powerful as the modulation factor escalates from 1.2x in 2026-2027 to 2.0x in 2028-2029.

Every strategy in this guide targets one or more of these levers. The most impactful changes address multiple levers simultaneously, such as switching to a lighter, more recyclable material.

Strategy 1: Switch From Multi-Layer to Mono-Material Films

Multi-layer flexible packaging is one of the most common Red-rated formats in UK packaging portfolios. Laminated pouches that combine polyethylene, nylon, aluminium, and other layers are extremely difficult to recycle because the layers cannot be mechanically separated at UK materials recovery facilities.

Mono-material alternatives, typically all-polyethylene (PE) or all-polypropylene (PP) structures, can achieve comparable barrier properties for many applications while qualifying for an Amber or even Green RAM rating. The technology has advanced rapidly, and several major film suppliers now offer mono-material alternatives with shelf-life performance close to traditional laminates.

Before and After

For producers with large volumes of flexible packaging, this single change can represent the largest fee reduction in their portfolio. The key barrier is often the technical qualification process. Plan for 6–12 months of testing and supplier engagement.

Strategy 2: Eliminate Carbon Black Pigment

Carbon black is the most common reason plastic packaging fails RAM Stage 3 (Sortation). Near-infrared (NIR) sensors at materials recovery facilities cannot detect carbon black pigmented plastics, meaning they fall through to residual waste regardless of whether the base polymer is technically recyclable.

The fix is straightforward: switch to a detectable dark pigment alternative. Several are now commercially available, including iron oxide-based pigments and specialist NIR-detectable blacks. They produce a visually similar dark colour while being fully sortable by MRF equipment.

Before and After

This is often the single easiest change a producer can make. The pigment cost difference is minimal, the visual result is nearly identical, and the switch can sometimes be made without retooling. It upgrades a component from Red directly to Green, the maximum possible rating improvement.

Strategy 3: Reduce Packaging Weight (Lightweighting)

EPR fees are charged per tonne. Reducing the weight of your packaging directly reduces the tonnage you report and therefore the fee you pay. This is the simplest lever available: less material means lower cost, regardless of RAM rating.

Lightweighting opportunities exist across virtually every packaging format. Common approaches include reducing wall thickness on bottles and tubs, optimising corrugated board flute profiles, downgauging flexible films, and removing unnecessary secondary packaging layers.

The constraint is product protection. Any weight reduction must maintain sufficient structural integrity, barrier performance, and shelf life for the packaged product. But many packaging formats carry more material than functionally necessary, often because the specification has not been reviewed since it was originally created.

Before and After

A 25% weight reduction on a high-volume format delivers a 25% fee reduction on that component. Multiply this across multiple SKUs and the savings compound quickly. Lightweighting also reduces material costs and transport costs, making it a triple-win.

Strategy 4: Convert Packaging to Mono-Material Design

Beyond flexible films (covered in Strategy 1), the principle of mono-material design applies across many packaging types. Multi-material packaging, where different materials are combined into a single component that cannot be easily separated by the consumer, consistently scores poorly in RAM assessments because it disrupts sorting and reprocessing.

Common multi-material offenders include:

• Paper cups with plastic lining – the PE lining contaminates paper recycling streams
• Card packaging with plastic windows – if the window is not easily detachable, the entire component may receive a lower rating
• Metal closures on glass or plastic containers – separable closures are generally acceptable, but permanently attached multi-material closures are not
• Fibre composite cartons (e.g., Tetra Pak style) – card, aluminium, and plastic layers combined into a single structure

Converting these formats to mono-material alternatives, or designing them so the different materials are easily separable by the consumer, can significantly improve RAM ratings and reduce fees.

Before and After

The saving per component may appear smaller for paper/card items due to the lower base rates, but producers typically have many such components across their range. Aggregate savings across 20–50 card packaging lines add up to meaningful numbers.

Strategy 5: Improve Your RAM Ratings Through Better Data

Not all Red or Amber ratings reflect genuine recyclability problems. Some reflect incomplete or inaccurate data in the RAM assessment itself. If you assessed your packaging using conservative assumptions because you lacked specific information about material composition, collection infrastructure coverage, or reprocessing capacity, you may have understated your recyclability.

Improving your data quality can improve your RAM rating without changing a single gram of packaging material. This involves:

• Verifying material specifications with your packaging suppliers to ensure you are reporting the correct polymer type, additives, and coatings
• Checking collection infrastructure coverage against the latest local authority data. Collection rates change as councils update their kerbside schemes
• Confirming separability claims for multi-component packaging. If the consumer can easily separate a label from a bottle or a plastic window from a card box, the component should be assessed as separable, which improves the rating
• Updating sortation assumptions based on the latest MRF capability data. Some facilities have upgraded equipment that can now sort materials previously considered unsortable

We regularly see producers improve ratings on 10–15% of their components simply by conducting a thorough data review. Each upgrade from Red to Amber, or Amber to Green, delivers direct fee savings.

Strategy 6: Switch Suppliers for Better Materials

Your packaging supplier's material specifications directly affect your RAM ratings. Different suppliers offer different material grades, and some are significantly more recyclable than others. For example:

• Some PET tray suppliers use crystal PET (CPET) which has limited recycling infrastructure, while others offer amorphous PET (APET) which is widely recycled
• Some label suppliers use full-sleeve shrink labels that interfere with sortation, while others offer partial labels or wash-off adhesive technologies that do not
• Some film suppliers offer mono-material alternatives where others only supply multi-layer laminates
• Some corrugated suppliers use excessive plastic tape and banding, while others use paper-based alternatives

Requesting recyclability specifications as part of your supplier evaluation process ensures that new packaging procurements are optimised for EPR fees from the outset. For existing suppliers, ask whether alternative specifications are available that would improve your RAM ratings.

Before and After

Strategy 7: Use Software to Continuously Optimise

The strategies above are not one-off actions. EPR fee rates change annually. RAM methodology updates alter the classification of certain materials. New recycling infrastructure comes online, upgrading collection and reprocessing capacity. Supplier material specifications evolve. Your own product range changes with new launches and discontinuations.

Managing all of this in spreadsheets is a recipe for missed optimisation opportunities and inaccurate fee projections. Packaging compliance software like Repackd provides:

• Automated RAM assessment for every packaging component, updated as methodology changes
• Fee projection modelling across all three modulation years, showing your total cost trajectory
• Material change simulation that lets you test "what if" scenarios and see the fee impact before committing to any redesign
• Supplier data collection workflows that make it easy to gather accurate material specifications from your supply chain
• Portfolio-level reporting that ranks your packaging components by fee exposure and highlights the highest-ROI optimisation targets

The cost of the software is typically recovered many times over through fee reductions. A producer paying £50,000 per year in EPR fees who achieves a 25% reduction through software-guided optimisation saves £12,500 per year, a return that far exceeds the subscription cost.

Putting It All Together: A Complete Before-and-After Example

Let us model a mid-market food producer handling 150 tonnes of household packaging who implements multiple strategies across their portfolio.

The total fee reduction is £11,850 per year by 2028-2029, representing a 34.6% saving. Over the three-year modulation period (2026-2029), the cumulative saving exceeds £25,000. And this is for a relatively modest 150-tonne producer. Larger businesses handling thousands of tonnes would see proportionally larger absolute savings.

Priority Matrix: Where to Start

Not every strategy suits every business. Here is a quick guide to help you prioritise.

Start with the low-effort, high-impact strategies (carbon black elimination and data quality improvement), then work through the medium-effort changes based on your portfolio composition, and invest in the longer-lead-time strategies for the biggest long-term savings.

The Cost of Doing Nothing

Every year you delay action, the cost increases. The modulation multiplier escalates annually, meaning Red-rated packaging becomes progressively more expensive relative to Green. A component that costs you an extra £2,000 per year at the 1.2x multiplier in 2026-2027 will cost £6,000 extra at 2.0x in 2028-2029. Over three years, that single component accumulates £12,000 in avoidable fees.

Multiply that across every Red-rated component in your portfolio, and the case for action becomes overwhelming. The producers who invested in packaging optimisation during 2025 and early 2026 are already seeing returns. Those who wait until the 2.0x multiplier hits will face the full cost with no lead time to implement changes.

EPR fee optimisation is not about spending more on packaging. It is about spending smarter. Every material change that improves recyclability reduces your compliance cost, your environmental impact, and your regulatory risk simultaneously.