By Ellis Clark, Head of Marketing at Tunley Environmental
For many organisations, Extended Producer Responsibility (EPR) is still being treated as a compliance task, something to submit and move on from. However, the businesses looking more closely at their packaging data are starting to realise something different: EPR is one of the clearest opportunities to reduce costs associated with packaging.
The reason for this is that EPR doesn’t just charge you for the volume of packaging you place on the market, it charges you based on how that packaging is designed, how recyclable it is, and how accurately it’s reported. That means two organisations with similar products can end up paying very different fees, depending on how well they understand and manage their data.
This is where many businesses are missing value. Packaging data is often incomplete, inconsistent, or pulled together at the last minute. Materials get grouped into broad categories, assumptions are made to fill gaps, and, in some cases, packaging is effectively treated as “worst case” just to ensure compliance. The result is that organisations can default into higher fee categories without realising it, paying more than they need to year after year.
An EPR assessment changes that. It looks beyond submission and focuses on what’s genuinely increasing cost. Through analysing packaging formats, increasing data accuracy, and identifying where materials fit within recyclability criteria, inefficiencies can be identified and exposure to higher fees reduced. It is about turning ambiguous data into unambiguous decisions and, in many cases, high-cost packaging into lower-cost alternatives.
As EPR reporting requirements continue to evolve, the organisations that treat EPR as a cost lever rather than a compliance exercise will be in a much stronger position, not only to stay compliant but also to actively reduce costs and make more informed packaging decisions over time.
The growing financial impact of EPR
One of the most significant developments within EPR is the introduction of modulated fees, which are designed to reflect the recyclability of packaging materials. From April 2026, these fees will be adjusted using the Recyclability Assessment Methodology (RAM), a framework that assigns each packaging format a recyclability rating. This marks a clear shift in direction, moving away from flat or generalised cost structures towards a more targeted approach that incentivises better packaging design.
Under RAM, packaging is assessed and categorised using a Red, Amber, or Green (RAG) rating system. Red-rated packaging is considered difficult to recycle, often due to material composition, lack of infrastructure, or contamination risks. Amber-rated packaging represents transitional materials, which may be recyclable under certain conditions but are not yet widely supported. Green-rated packaging, on the other hand, is widely recyclable and aligns with existing collection and processing systems.
This classification system has direct financial consequences. Packaging that falls into the Red category will incur increasing surcharges over time, with a 20% increase applied in 2026–27, rising to 60% in 2027–28, and reaching 100% by 2028–29. In contrast, Green-rated packaging will benefit from reduced fees, with the exact level of discount determined by the scheme administrator. This structure is designed to encourage organisations to move away from difficult-to-recycle materials and towards more sustainable alternatives.
While the intention of this system is to support the transition to a circular economy, it also introduces a level of financial exposure that many organisations have not previously had to manage. Packaging decisions that were once driven by cost, functionality, or branding must now also account for recyclability and compliance costs. As a result, businesses that do not fully understand how their packaging is assessed may find themselves facing higher fees than expected.
Why many organisations are overpaying
Despite the increased focus on EPR, many organisations are not yet fully equipped to manage these new requirements efficiently. EPR reporting often relies on data that is inconsistent or incomplete. Packaging information may be stored across multiple systems, owned by different departments, or sourced from suppliers who do not provide the level of detail required for accurate reporting.
This creates several areas where unnecessary costs can arise. In some cases, organisations may over-report packaging volumes due to duplication or conservative assumptions, leading to inflated fees. In others, materials may be incorrectly classified, resulting in packaging being assigned a higher-cost category than necessary. There may also be gaps in data, particularly for imported goods, where visibility over packaging composition is limited.
These challenges are compounded by the fact that EPR reporting requirements are still evolving. As guidance becomes more detailed and enforcement increases, the margin for error is reduced. What may have been acceptable in earlier reporting cycles may no longer meet the required standard, increasing the risk of non-compliance or financial penalties.
Without a structured approach, organisations can find themselves reacting to EPR requirements rather than managing them proactively. This can increase the administrative burden and make it more difficult to identify opportunities for cost reduction.
The role of an EPR assessment
An EPR assessment provides a structured way to address these challenges by bringing together data, processes, and packaging design into a coherent view. It allows organisations to understand how their packaging decisions translate into reporting requirements and into cost.
The first step in an EPR assessment is typically to establish an understanding of your obligations. This involves reviewing your products, packaging formats, and market activities to determine which regulations apply and what data needs to be reported. For organisations operating across multiple regions, this can be particularly important, as requirements may differ between jurisdictions.
EPR regulations and producer organisations
UK EPR packaging regulations
- UK Producer Responsibility Regulations
- UK Packaging Data Reporting Requirements & Submissions Processes
EU EPR packaging regulations
- EU Packaging & Packaging Waste Directive
- EU Waste Framework Directive
US and Canada EPR packaging regulations
- Oregon EPR
- Colorado Producer Responsibility for State-Wide Recycling Act
- Minnesota Packaging Waste & Cost Reduction Act
- Washington State EPR Legislation
- Maine Stewardship Program for Packaging
- California Plastic Pollution Prevention & Packaging Producer Responsibility Act (SB 54)
- Maryland Packaging & Paper Product EPR
Relevant producer organisations
- APR Design Guide for Plastics Recyclability
Once obligations are defined, the focus shifts to data collection and validation. This involves gathering detailed information on packaging materials, weights, and formats, and ensuring that this data is accurate and consistent. In many cases, this process highlights discrepancies or gaps that would otherwise lead to incorrect reporting.
From there, the assessment can begin to identify cost drivers. By mapping packaging formats against RAM criteria, it becomes possible to see which materials are likely to attract higher fees and where there may be opportunities to improve recyclability. This does not necessarily require a complete redesign of packaging; in many cases, relatively small changes, such as simplifying material composition or improving labelling, can have a tangible impact on recyclability scores.
Reducing costs through better data
One of the most immediate benefits of an EPR assessment is improved data quality. While this may seem like an operational detail, it has a direct impact on cost. Accurate data ensures that organisations are only reporting what is required, avoiding overpayments caused by duplication or incorrect assumptions.
It also enables more precise classification of packaging materials. Rather than defaulting to higher-cost categories due to uncertainty, organisations can confidently assign materials based on verified information. This reduces the risk of overpaying while also supporting more robust compliance.
In addition, better data creates a stronger foundation for future reporting. As EPR reporting requirements become more detailed, organisations with well-structured data systems will be better positioned to adapt. This reduces the time and effort required for each reporting cycle, lowering administrative costs and freeing up internal resources.
Influencing packaging design decisions
Beyond data, an EPR assessment also provides valuable insight into how packaging design influences cost. By understanding how different materials and formats are assessed under RAM, organisations can make more informed decisions about future packaging strategies.
This does not mean that all packaging must immediately shift to Green-rated materials. In many cases, there are practical constraints related to product protection, supply chain requirements, or customer expectations. However, having visibility over the cost implications of different options allows organisations to make balanced decisions that consider both functionality and compliance.
Over time, this can lead to a more strategic approach to packaging design. Rather than reacting to regulatory changes, organisations can plan ahead, gradually transitioning towards more recyclable formats and reducing their exposure to increasing fees. This supports compliance and aligns with broader sustainability objectives.
Streamlining internal processes
Another important aspect of an EPR assessment is the opportunity to improve internal processes. EPR reporting often involves multiple teams, including procurement, operations, sustainability, and finance. Without coordination, this can lead to inefficiencies, duplicated effort, and inconsistent data.
Organisations can reduce these inefficiencies by developing structured processes for data collection, validation, and reporting. This could involve standardised templates, specific roles and responsibilities, and systems for tracking packaging data over time. Although these changes may seem operational in nature, they are an important part of making sure that EPR reporting is accurate and efficient.
Moreover, optimised workflows allow for scalability over time. As organisations grow or expand their footprint in new markets, a consistent approach to EPR makes it easier to manage additional reporting obligations without introducing significant complexity.
Looking beyond compliance
While the primary driver for EPR is regulatory compliance, the process of assessing and improving packaging data can deliver wider benefits. Organisations that take a proactive approach often find that they gain a deeper understanding of their packaging footprint, including material usage, waste generation, and opportunities for improvement.
This insight can support a range of broader objectives, from reducing environmental impact to improving operational efficiency. It can also strengthen engagement with suppliers, as organisations work collaboratively to obtain more accurate data and explore alternative materials.
In this sense, EPR can act as a catalyst for change. Rather than being seen solely as a compliance burden, it can provide a framework for making more informed and sustainable decisions.
Preparing for what comes next
As EPR reporting requirements continue to develop, the expectations placed on organisations are likely to increase. This includes more detailed data requirements, stricter enforcement, and greater alignment with international frameworks. For organisations that are not yet fully prepared, this presents both a challenge and an opportunity.
An EPR assessment offers a way to get ahead of these changes by establishing a clear understanding of your current position and identifying practical steps for improvement. By addressing data quality, refining packaging design, and streamlining processes, organisations can reduce their exposure to rising costs while building a more resilient approach to compliance.
The value of an EPR assessment ultimately is that it makes a complex and evolving requirement manageable. It offers clarity, structure, and actionable insight that enable organisations to shift from reactive compliance to a more strategic approach that not only meets regulatory expectations but generates tangible commercial benefits over time.
