UK pEPR: Ecosurety talks navigating cost-saving and reporting strategies

The UK’s packaging EPR (pEPR) requires data reporting and non-compliance fees that are a challenge for many producers, large and small, according to Jon Brookes, Ecosurety’s partnerships director. 

As the first month of pEPR comes to an end, MPs are set to hold a debate on the impact of the pEPR in Westminster Hall next week. Packaging Insights sits down with the compliance specialist to discuss what packagers operating in the UK need to be aware of.

Discussing how realistic it is for packaging producers to adapt quickly enough to offset pEPR costs, Brookes tells us: “The way the system works means there is a lag in being able to change strategy and impact costs.”

Many producers are only just now waking up to this reality, according to the expert.

“For example, costs in 2026 are defined by packaging [and products] sold in 2025, much of which was designed and procured in 2024 and earlier. Rolling this forward means that many producers will find it difficult to move quickly to impact their costs in 2027,” says Brooks.

He adds that acting to impact 2027 costs is nonetheless still possible, but only if packagers act fast, according to the products going to market next year.

Regulatory uncertainty effects

The pEPR fees became applicable at the start of October. Earlier this month, the UK government proposed changes to the legislation text, while the retail industry complained about rising costs and a lack of investment in waste management infrastructure.

Jon Brookes, partnerships director at Ecosurety.Brooks highlights supply chain constraints as a key issue for packagers facing pEPR compliance rules, while adding that regulatory uncertainty may be “a bigger concern in the long term.”

“For example, the status of flexible plastic against the Recyclability Assessment Methodology (RAM) may change in two years’ time once Simpler Recycling comes in and mandates collection of flexibles at curbside. However, without having certainty on this, producers may move to other materials.”

RAM aims to help packaging companies facilitate the collection and sorting of packaging waste by adapting their designs according to a traffic light classification of materials.

“This [change in material status] could have unintended consequences for the market, particularly for recycling infrastructure, which needs a view of the material mix coming on stream in order to make key infrastructure investments, in what is already a very challenged sector.”

The RAM technical advisory committee has now been established. Brookes expects this to translate into “timely and clear signals to producers around when and how the methodology will change in the coming years, so packaging strategies can be effectively planned.”

Balancing cost and compliance

Brookes assures Ecosurety continues to use its “unique position, technical expertise, and data capabilities” to assist its clients in managing pEPR costs, while ensuring they are looking at their packaging design “holistically” and taking environmental impact into account.

“Our mission as a compliance scheme is to rid the world of unnecessary packaging,” he asserts.

Ecosurety leverages data to ensure that pEPR fees are incentivizing packagers to move beyond single-use products and making reusable packaging more attractive from a cost perspective.

“Given the scale of the new UK pEPR fees, we are having more and more conversations with producers about what circular solutions are available to them.”

Reporting for small producers

Ecosurety agrees that local councils should use pEPR funds to invest in packaging waste management.Comparatively smaller packaging companies are finding pEPR reporting “especially challenging,” acknowledges Brookes.

“They are often under-resourced to be able to manage the process of pEPR reporting and the data requirements for it. We are supporting smaller producers where we can with relevant compliance advice and data services,” he continues.

“For smaller companies, although the absolute costs of pEPR may be small, the relative costs of pEPR when there are wider concerns about margin and operating costs can make this a significant issue for them.”

“This said, governments are aware and have tried to mitigate the pEPR burden for small producers via less granular and less frequent data reporting obligations.”

Mitigating price hikes

Following the start of pEPR fee collection, the British Retail Consortium (BRC) stated that over 80% of costs “are likely to be passed onto already hard-pressed consumers,” following a survey of “leading retailers.”

Brookes says Ecosurety cannot comment on the pricing decisions of its members or other obligated producers under pEPR.

“While individual pricing strategies adopted by liable brand-owners will ultimately determine the cost passed on to consumers, Ecosurety remains optimistic that — in addition to further recyclability incentives resulting from modulation next year — EPR fees will act to improve packaging credentials as producers seek to mitigate costs.”

“We are already engaged in constructive conversations with our members around packaging strategy, including how reuse can be scaled effectively,” adds Brookes.

“Therefore, it is not clear to us that all pEPR costs will be passed through to the consumers as price rises.” 

Ecosurety agrees with the BRC in its assertions that pEPR funds allocated to local authorities “should drive tangible steps toward circularity and therefore be used to increase quality collection, sortation, and recycling of packaging waste.”