New report finds fibre based composite pEPR fees may have been overpaid by between £6.3m and £13.7m
A new report published by compliance scheme Beyondly, commissioned by ACE UK, has found that producers of fibre-based composite (FBC) packaging like liquid cartons, sandwich wrappers and ready meal containers may have been significantly overcharged by the Extended Producer Responsibility (EPR) scheme.
The report found that the £461 per tonne pEPR fee charged by PackUK for FBCs has been incorrectly calculated, with the true figure being £34/t lower on a conservative analysis of available data sources, and potentially as high as £92/t. Applied to the fees paid by brands for FBC materials last year, this suggests that fees could have been overpaid by between £6.3m and £13.7m.
The report also identifies several areas where current assumptions materially overstate the cost burden applied to FBC packaging. The most significant issue relates to the cost to local authorities of collecting packaging for recycling or disposal, with the scheme currently charging £509/t to collect FBC compared with just £264/t for paper and card despite the two having very similar properties.
Charlotte Davies, Senior Consultant for Resource Efficiency & Circularity at Beyondly said: “The current fee of £461/tonne appears to be disproportionately high for fibre-based composites.
“The review identifies two key drivers of overcharge. The bulk density assumed for non-liquid cartons is based on corrugated cardboard rather than the lighter retail packaging formats that dominate kerbside FBC waste.
“The market split between liquid and non-liquid cartons also overstates the share of low-density liquid cartons. Since recyclate collection costs represent nearly two-thirds of FBC waste-management costs and are apportioned by volume, both factors inflate the volume allocated to FBC waste and therefore the proportion of collection cost it bears.
“Combined, data revisions could reduce the disposal fee by approximately 8%. The review also highlights widespread misreporting of FBCs as paper and card and demonstrates the influence this had on disposal fee cost for 2025.”
In addition to the immediate concerns around collection costs, the review also highlights a number of other issues, which may further overinflate the FBC fee and recommends further research and analysis of data.
Ben Powell, Head of External Affairs, ACE UK said: “This report shines a light on the true extent of the artificially high pEPR disposal fees charged to producers of FBC packaging, including liquid cartons.
“It is clearly implausible to charge nearly twice as much for local authorities to collect a tonne of FBC than a tonne of paper and card. The impact of this discrepancy alone seems to have cost brands millions of pounds more than it should have done last year.
“As the pEPR system beds in, we know that the data and assumptions used will continue to improve, leading to a more accurate cost being applied to every package on the market. We were really pleased to work with Beyondly on this excellent report, which offers robust recommendations backed up by evidence.
“We look forward to continuing to work constructively with PackUK to ensure disposal fees are fair for all packaging types, which is essential if we want to make our shared sustainability goals a reality.”
A copy of the report can be requested by email to ACEUK@contextpr.co.uk.