December 2025: the Government has proposed Year 2 disposal fees for Extended Producer Responsibility (EPR) for packaging in the UK. In Year 1 (2025/26), all packaging of a particular type pays the same base rate regardless of recyclability. From Year 2, red-rated packaging (difficult to recycle) pays 20% more than amber (the new base rate), while green-rated packaging (widely recyclable) gets a 9% discount. The premium imposed on red-rated material is set to increase to 60% in Year 3 (2027/28) and 200% in Year 4 (2028/29).
45% of plastic packaging is rated red under Defra's Recyclability Assessment Methodology (RAM).A breakdown of RAM ratings reported by producers shows the split across categories:
45% of plastic packaging is red-rated – meaning it fails recyclability criteria – and only 31% achieves a green rating.
RAM assesses packaging through five stages: classification, collection, sortation, reprocessing, and end markets. A red result at any stage produces an overall red rating.
Some plastics receive automatic red classification: packaging using carbon black pigment, which prevents near-infrared sorting; PVC in any form; polystyrene including expanded and extruded forms; oxo-degradable, and biodegradable or compostable plastics.
Flexible plastic packaging faces a particularly stringent threshold. Films, pouches and sachets must contain at least 80% polyethylene or polypropylene by weight to avoid red classification. This effectively renders most multi-layer flexible laminates red-rated – including crisp packets (metallised plastic film combining multiple polymer layers), sauce sachets, coffee pouches and pet food packaging.
Green ratings are achievable for clear PET, natural HDPE, and clear PP pots and tubs, all widely collected at kerbside and compatible with existing reprocessing infrastructure. This table shows fees per unit:
A company making one billion crisp packets annually would face an additional cost of around £260,000 per year. This is hardly a big incentive to change, and may well be cheaper than switching to recyclable alternatives.
A clear PET bottle – green-rated due to wide kerbside collection and established recycling infrastructure – would pay the lower fee. A 500ml bottle weighing around 25g works out at 40,000 units per tonne, with a fee of approximately 1.04p per bottle at the green rate.
This summary is taken from a much longer article: EPR fees set as 45% of plastic packaging rated unrecyclable | Charles Newman for Resource.co, 17 December 2025. For full details go to Extended producer responsibility for packaging| Defra, 19 December 2025; for more on RAM see Recyclability Assessment Methodology | Defra 4 September 2025. You probably need to be a packaging manufacturer to want to read these.
Originally posted in Second Nature 047 (January 2026). Category: plastics, tags packaging, SN047.
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