UK Packaging Regulations for Foodservice and Retail Buyers

What are the main UK packaging regulations for foodservice buyers?

Six regimes matter most: packaging EPR (pEPR), Plastic Packaging Tax, single-use plastic bans in each nation, carrier bag charges, food-contact law, and consumer protection rules on environmental claims. Simpler Recycling in England adds a workplace waste duty.

Who is the producer under UK pEPR?

Under pEPR, you are a producer if you are UK-established, have a turnover above £1 million and handle more than 25 tonnes of packaging a year through activities such as brand owning, packing, importing packaged goods or supplying unfilled packaging you manufacture or import. Large producers, above £2 million turnover and more than 50 tonnes, pay the waste management fees; smaller producers mainly register and report data. A non-UK manufacturer is not the producer; the UK importer or brand owner is.

Brand owner or restaurant chain

If packaging carries your brand, you are typically the producer for it, provided you meet the thresholds. Service packaging, the bags, cups, wraps and boxes filled at the point of sale, has its own rules on who reports and pays, so check the gov.uk guidance for service packaging rather than assuming the general brand-owner rule. Franchise networks should clarify whether the franchisor reports for the network.

Importer

If you import packaging or packaged goods into the UK and meet the thresholds, importing is a producer activity in its own right. When printed takeaway packaging is bought from a manufacturer in Türkiye, the EU or elsewhere, the UK importer, often the chain itself or its distributor, picks up the obligation.

Distributor

A UK distributor that imports unfilled packaging and sells it to restaurants can be the producer for that packaging as importer or seller of unfilled packaging. Agree in your supply contract who reports which tonnages, so that the same packaging is not reported twice or missed entirely.

Foreign manufacturer

A manufacturer outside the UK is not a UK producer under pEPR. Its practical role is to supply accurate data: material, weight per item and per component, and information needed for the recyclability assessment. That data flows into its UK customer's report.

Fees and recyclability modulation

Base fees for year 1 were invoiced from October 2025. From year 2 (2026/27), fees are modulated by each item's recyclability assessment methodology (RAM) rating of green, amber or red. How the fees are built, what the RAM checks and what to budget are explained in the next section.

Recyclability labelling

The mandatory "Recycle" / "Do not recycle" labelling originally planned under pEPR has been removed from the regulations pending alignment, and no new date has been set. OPRL labelling remains voluntary. Keep a label panel in artwork so you can add a mandated mark later without redesign.

UK packaging EPR fees and RAM ratings explained

A large producer pays a waste disposal fee per tonne of household packaging, set by material, and from 2026/27 that rate also depends on whether each item is rated green, amber or red under the recyclability assessment methodology (RAM). The producer carries out the assessment itself, using data from its packaging supplier. An item with no assessment, or without the data to complete one, is rated red.

How base fees and modulated fees work

PackUK, the scheme administrator, calculates a fee per tonne for each of eight material categories from the net cost of collecting and managing household packaging waste, using the tonnages producers report. In year 1 (2025/26) every tonne of a material paid the same base fee. In year 2 (2026/27) the amber fee is the base rate; red-rated packaging pays a multiple of it and green-rated packaging pays less. According to the illustrative year 2 fees published on gov.uk (19 December 2025):

• Red = 1.2 x the amber fee in year 2, rising to 1.6 x in year 3 and 2 x in year 4.
• Green is provisionally about 9 % below amber. The green discount is not fixed: it depends on the share of red, amber and green tonnage producers place on the market, because the red uplift funds it.
• Fees apply only to household packaging, which includes packaging that commonly ends up in public bins. Primary packaging, including takeaway service packaging, is treated as household unless the producer can evidence that it goes to a business end user and is unlikely to reach a household or public bin.

Source: Defra/PackUK, year 2 illustrative waste disposal fees, December 2025. These are not final fees. Producers had until 1 September 2026 to resubmit 2025 data; PackUK will then calculate confirmed 2026/27 fees and issue notices of liability, with the initial notice planned for the end of November 2026 in its 2026/27 operational plan. As of October 2026 confirmed year 2 fees have not been published. Once a notice arrives, producers have 50 calendar days to pay, with an instalment option.

The material category matters as much as the rating. Fibre-based composite costs more than twice as much per tonne as paper and board, so the weight of the plastic layer on a coated board item can change its category, and with it the fee, before the RAG rating is even applied.

What is the RAM recyclability assessment?

The RAM is Defra's method for rating each packaging unit, or each separable component, red, amber or green. It checks four stages: whether the item is collected at kerbside across the UK, whether it can be sorted, whether it can be reprocessed at scale, and whether the recyclate can be reused in a typical application. The worst stage sets the overall rating.

• Green: widely recyclable in current UK infrastructure.
• Amber: some loss or difficulty in collection, sorting or reprocessing, or a need for specialist infrastructure.
• Red: difficult to recycle at scale.

Only large producers must assess and report, and only for household packaging. Exempt items include exported packaging, non-household packaging and PET, steel and aluminium drinks containers within an operating deposit return scheme. RAM version 1.1 (gov.uk, updated 4 September 2025) applies to the 2025 and 2026 reporting years; RAM 2027 (materials assessment guidance published 20 August 2026) applies to packaging supplied from 1 January 2027, and the method is reviewed each year. Because fees are calculated from the previous year's data, the 2025 assessments drive 2026/27 fees.

Some items are red whatever their material, the so-called automatic reds. They include packaging with intentionally added PFAS (except where aluminium, steel or glass is the main material), substances of very high concern above UK REACH thresholds, printing inks not made in line with the EuPIA Exclusion Policy, integrated electronics, and any in-scope household packaging that has not been assessed.

How paper and board packaging is rated

Each component is assessed under the material that forms most of its weight; parts the consumer can separate, such as a plastic lid on a paper container, are assessed separately. For fibre-based items the plastic share decides the route: fibre-based composite with 5 % plastic by mass or less is assessed as paper and board, and above 5 % it is assessed as fibre-based composite. The calculation counts fibre, fillers, papermaking additives and mineral colour coating as paper content. The main triggers under RAM version 1.1 for paper and board are:

For fibre-based composites over the 5 % plastic threshold, double-sided plastic lamination (for example PE/paper/PE) and more than 15 % non-paper content are red, and more than 10 % non-paper content is amber. Plastics follow separate rigid and flexible rules (carbon-black pigments, for example, are red because sorting machines cannot detect them).

Two of these rows decide everyday foodservice formats. Greaseproof wraps are red under the current method, and RAM 2027 keeps them red: it defines the category as fibre densification (greaseproof paper) or a continuous wax or silicone surface layer, and exempts wax dispersion coatings and silicone in linerless labels (wax dispersions remain an amber trigger). For UK budgets, see the greaseproof paper recyclability guide. Moulded bagasse bowls start at amber unless test evidence is supplied. Coating options that keep board in the paper stream are compared in barrier coatings for paper packaging.

What to ask an overseas packaging manufacturer for RAM and fee reporting

The producer signs the assessment, but most of the evidence sits with the manufacturer. An overseas supplier is not liable under pEPR, so the obligation to ask, and to keep the evidence, stays with the UK importer or brand owner. For each item, request:

Ask for the data per SKU in a format that matches your reporting file, and ask to be told before any material, coating or ink change, since a supplier substitution can move an item from green to amber. 9 Packaging, as an Istanbul-based manufacturer exporting printed packaging to UK buyers, confirms these material and component details for each item at quotation and technical review.

Worked example: how RAM ratings change a fee budget

The figures below are illustrative only. They use the December 2025 illustrative year 2 fees, assumed tonnages and assumed ratings for a chain that is a large producer. Your own ratings come from your assessment and your actual fees from your PackUK notice of liability.

Two specification changes would move this budget. If the boxes moved to a lighter barrier and a window-free design that keeps plastic at or under 5 %, and passed as paper and board green, their line would fall from £10,500 to £3,800. If the wraps switched from a greaseproof grade to a grease-resistant paper that the RAM rates green, their line would fall from £2,500 to £1,900. Together that is about £7,300 a year, around 39 % of the illustrative total, before the red multiplier rises to 1.6 x in year 3. Any material change still has to pass food-contact, grease and heat performance tests, so treat the RAM rating as one input to the specification, not the only one. Cost drivers outside EPR are covered in packaging cost drivers.

How does Plastic Packaging Tax work?

Plastic Packaging Tax applies to plastic packaging manufactured in or imported into the UK that contains less than 30 % recycled plastic, at £228.82 per tonne from 1 April 2026. Any business that manufactures or imports 10 tonnes or more of plastic packaging in 12 months must register with HMRC, whether the packaging is filled or unfilled.

For foodservice buyers, PPT is mainly relevant to plastic carrier bags, pouches, film windows, cup lids and container lids, and to paper packaging where plastic is the heaviest material by weight. Paper cups and boxes with a thin PE coating are normally paper by weight, but check the weight split for each item. Ask your supplier for the plastic weight and the recycled plastic percentage, supported by evidence, before the goods ship. Plastic carrier bag specifications are covered in plastic carrier bag regulations in the EU, UK and US.

What single-use plastics are banned in England, Scotland and Wales?

England has banned single-use plastic plates, trays, bowls, cutlery, balloon sticks and expanded or extruded polystyrene food and drink containers since 1 October 2023, including plastic-coated paper versions. Scotland's ban has applied since 1 June 2022 and Wales's since 30 October 2023. Exemptions differ, notably for items that count as packaging and for business-to-business supply. In England, plates, bowls and trays that are pre-filled or filled at the point of sale (for example at a takeaway, bakery, canteen or pub counter) count as packaging and are exempt.

The detail matters for paper packaging: in England a PE-coated paper plate or bowl sold empty to the public is caught, while the same item filled with food at the counter is packaging and exempt. Check the guidance for each item and nation. Cup-specific rules are in paper cup rules in Europe and the UK.

Do UK carrier bag charges apply to paper bags?

In England the minimum 10p charge applies only to single-use plastic carrier bags (up to 70 microns); paper bags are not charged. Scotland (minimum 10p since 1 April 2021) and Wales (minimum 5p since 1 October 2011) operate charges that also cover single-use paper bags, and Northern Ireland's 25p levy (since 1 April 2022) applies to new carrier bags of any material retailing at £5 or less; exemptions differ by nation. Specification and charge details for paper are in paper bag regulations by market.

How does food-contact law apply in the UK?

Great Britain retained EU food-contact law as assimilated law: Regulation 1935/2004 (framework), 2023/2006 (good manufacturing practice) and 10/2011 (plastics). Northern Ireland follows current EU rules under the Windsor Framework. A Declaration of Compliance should reference the legislation for the market concerned. Our food-contact packaging compliance guide explains DoC contents and supplier documents.

What else affects UK packaging buyers?

• Simpler Recycling (England): since 31 March 2025, businesses with 10 or more full-time equivalent employees must separate recyclable waste for collection; plastic film, originally due by 31 March 2027, has been delayed to 2030 following a July 2026 Defra announcement. For restaurants this affects back-of-house waste streams and makes recyclable packaging easier to manage on site.
• Green claims: the CMA Green Claims Code sets out how environmental claims must be truthful, clear and substantiated. Under the Digital Markets, Competition and Consumers Act 2024, the CMA can impose fines of up to 10 % of global turnover for consumer law breaches since April 2025. Claims such as "eco-friendly" or "compostable" on printed packaging need evidence; see recyclable, compostable and biodegradable packaging.
• Importing from Türkiye: the UK-Türkiye free trade agreement has applied since 1 January 2021, but preferential treatment depends on meeting product-specific origin rules and providing an origin declaration. UK import VAT applies. The practical steps are in sourcing packaging from Türkiye.

UK packaging timeline

Documents to request from your packaging manufacturer

• Weight per item, split by material (paper/card, plastic, other) and by component, in the format your pEPR reporting needs.
• Recyclability information for RAM assessment: coating type and weight, windows, laminates, inks and finishes (the full list is in the EPR fees and RAM section above).
• Plastic weight and recycled plastic content per item, with evidence, for Plastic Packaging Tax.
• Food-contact Declaration of Compliance referencing GB (and, if relevant, EU/NI) legislation.
• Evidence for any environmental claim printed on the packaging.
• Origin information needed for preferential tariff treatment, where claimed.

When buying from an overseas manufacturer such as 9 Packaging in Istanbul, agree at quotation and technical review which data and declarations will accompany each delivery, since they depend on the materials and construction of each item.

What this means for foodservice and retail packaging

• Paper cups: pEPR data, coating choice for RAM rating, SUP Directive marking if also sold in the EU. See custom printed paper cups.
• Takeaway boxes: check SUP ban exemptions for plastic-coated items, and RAM rating for coatings. See custom printed takeaway food boxes.
• Paper carrier bags: no charge in England, but charges in Scotland, Wales and Northern Ireland. See custom printed paper carrier bags.
• Plastic bags: PPT recycled content threshold, carrier bag charge, Welsh rules to watch. See custom printed plastic bags.
• E-commerce boxes: pEPR reporting as brand owner or importer; claims on boxes need substantiation.

Next step: build your UK packaging data sheet

For each item, record material weights, plastic content, recycled content, coating type, nation of use and who reports under pEPR. Request the missing data from your supplier before the next order. If you are specifying new packaging for the UK, include these requirements in your request for quotation or send them through our contact page.

Related reading

• PPWR Explained for Foodservice and E-commerce Packaging Buyers
• PPWR Labelling Requirements: Harmonised Sorting Labels, Timelines and Who Must Label