EPR fee modulation explained

The mechanism

Waste disposal fees under packaging EPR are charged per tonne by material. Modulation adjusts that rate according to the recyclability rating of household packaging, which comes from the Recyclability Assessment Methodology. The structure is simple enough to hold in your head:

• Amber is the base fee. It is the rate everything is measured against, which is why amber is the sensible default assumption for planning.
• Red pays a multiplier of 1.2 times the amber rate for the material.
• Green pays less, by an amount that is not knowable in advance. The green discount is variable and depends on how much red-rated packaging is placed on the market overall. In illustrative material for 2026/27 the discount was estimated at around 9%, which is 0.91 times the amber fee. That is an estimate published alongside illustrative rates, not a rate you can rely on.

The Year 2 illustrative rates

The figures BeautyPack ships with are the Year 2 illustrative modulated base fees for 2026/27, published by Defra and PackUK in December 2025 and rounded to the nearest £5. They cover 1 April 2026 to 31 March 2027 and are per tonne, as green, amber and red:

• Aluminium: £245, £270, £325
• Fibre-based composite: £475, £525, £630
• Glass: £185, £205, £245
• Paper or board: £190, £210, £250
• Plastic: £415, £455, £545
• Steel: £260, £290, £345
• Wood: £410, £450, £540
• Other: £205, £225, £270

The source is Year 2 illustrative waste disposal fees: extended producer responsibility for packaging on GOV.UK. Read the word illustrative literally. Confirmed rates for 2026/27 were due after the 1 April 2026 reporting deadline, and confirmed rates for later years will follow the same pattern of arriving after the data does. Any number you circulate internally should carry the rate set name, its status and its publication date beside it.

What the difference actually looks like

Take plastic. Amber is £455 per tonne illustratively. Red is £545. On 40 tonnes of household plastic packaging, which is a mid-sized beauty range, the difference between an entirely amber portfolio and an entirely red one is about £3,600 a year at those rates. That is not a number that changes a business, and it is worth saying so plainly rather than overselling the case. What changes the business is the direction of travel: rates have risen between years, the green discount is real, and portfolios that cannot answer RAM questions at all default to red across the board.

Fibre-based composite is the outlier worth watching in beauty, at £525 amber and £630 red. Multi-material cartons and composite tubes carry a materially higher rate than paper or board, so a pack that reads as cardboard to a designer may not be reported or charged as cardboard.

Building a forecast you can defend

A fee forecast is a chain of assumptions, and it is only useful if every link is visible. Build it in this order.

1. Tonnage by material and rating. Component weight multiplied by units supplied, aggregated by EPR material category, split household and non-household, with the RAM rating attached to the household portion.
2. Rate set. Name it. Year 2 illustrative 2026/27 is a different thing from a confirmed rate set, and mixing them silently is how a board paper becomes wrong.
3. Modulation assumptions. State that red is 1.2 times amber, and state what you assumed for green. Running one scenario with no green discount and one at the illustrative 9% is more honest than picking one.
4. Treatment of unknowns. Decide explicitly how items with missing facts are counted. Counting them as red is the prudent choice and matches how the methodology treats unsupported claims, but say that you did it.
5. Scope caveats. Modulation applies to household packaging ratings. Confirm the current scope and any exclusions with PackUK rather than inferring them.

Present the result as an indicative forecast with a range, not as a fee. Estimates like this are not Notices of Liability, and the gap between the two is exactly the set of assumptions you just listed.

Checklist

• Assume amber as the base case for anything unrated.
• Model red at 1.2 times amber and green as a scenario, not a saving.
• Label every figure with the rate set, its status and its publication date.
• Re-run the forecast when confirmed rates are published, and keep the old version.
• Check the number of tonnes before you argue about the rate per tonne.

Our EPR overview for beauty brands covers how tonnage is reported in the first place, which is where forecast accuracy really comes from.