Plastic Packaging Tax and EPR for UK food makers

The short answer is that the Plastic Packaging Tax (PPT) is charged on the manufacturer or importer of the plastic packaging, not on you as a buyer. But it ends up in the price you pay, and HMRC can pursue businesses further down the chain. Separately, EPR (extended producer responsibility) is a fee on the packaging you put on the market, and you may well be liable for it directly.

Here's what each one means for a food manufacturer turning over £1m to £10m, and what you should be asking your suppliers.

Who pays Plastic Packaging Tax?

PPT applies to plastic packaging made in or imported into the UK that contains less than 30% recycled plastic. The rate is £228.82 a tonne from 1 April 2026.

Liability sits with the UK manufacturer or importer. You register once you make or import 10 tonnes or more of plastic packaging in a 12 month period. A food manufacturer buying wrap, film and bags from a UK supplier usually isn't the one registered.

The rate has crept up each year. It was £200 a tonne in 2022, £210.82 in 2023, £217.85 in 2024 and £223.69 in 2025. That adds up, and a supplier who makes or imports plastic wrap passes it down the chain in the price.

What's the 30% recycled content rule?

If a plastic packaging component has at least 30% recycled plastic by weight, it's outside the tax. Below that, the tax applies.

That makes the recycled content figure matter. A roll of wrap with 30% or more recycled plastic is outside the tax. One at 25% isn't.

So your supplier's price already reflects which side of the line the film falls on. If you can't tell which side, you can't judge the price.

Can a buyer be held liable for plastic tax?

In some cases, yes. HMRC can make other businesses in the supply chain secondarily or jointly liable for unpaid PPT. When it does, it takes into account whether you recorded your due diligence.

You're unlikely to be the first in line, but "we didn't ask" is a weak position. Records of what you asked, and what the supplier said, are your protection.

Not sure what's sitting in your packaging, or what evidence you hold? We'll walk through it with you on site.

Who has to pay EPR packaging fees?

EPR is a different system. It makes producers pay the cost of dealing with the packaging they supply. You can count as a producer as a brand owner, a packer-filler or an importer, so a food manufacturer putting packed goods on the market usually is one. For now, the waste disposal fee is calculated only on the packaging you report as household packaging, the packs that end up in people's homes. Your pallet wrap and transit packaging still has to be reported, but it isn't charged at the moment.

The thresholds work by turnover and tonnage. Under £1m turnover, or under 25 tonnes of packaging, you have no obligation. A small producer is one with £1m to £2m turnover and over 25 tonnes, or over £1m with 25 to 50 tonnes. Small producers report data but don't pay fees. A large producer, with over £2m turnover and over 50 tonnes, reports data and pays fees.

Many food makers in the £1m to £10m range will sit in one of the upper two groups. Check which, because the difference is a fee bill.

What do large producers actually pay?

Fees are charged per tonne by material. In Year 1 (2025 to 2026), the base fees per tonne were £423 for plastic, £196 for paper and card, £266 for aluminium, £192 for glass, £259 for steel, £280 for wood and £461 for fibre composite.

Say a manufacturer with over £2m turnover puts 12 tonnes of plastic and 45 tonnes of paper and card household packaging on the market in a year. That's 57 tonnes, so a large producer. At Year 1 rates the fee is about £5,076 for plastic and £8,820 for paper and card, around £13,900. That's an illustrative example, not a forecast, and it only counts household packaging.

For Year 2 (2026 to 2027), the only per tonne figures we could find on GOV.UK are illustrative. They show plastic at £415, £455 or £545 a tonne and paper and board at £190, £210 or £250, depending on a green, amber or red rating. When we looked in October 2026 we couldn't find confirmed Year 2 fees, so treat these as indicative and check GOV.UK and PackUK before budgeting.

What does this mean for a £1m to £10m food manufacturer?

Three costs, none of them obvious on the invoice.

The first is the unexpected cost. EPR fees arrive as a bill for packaging you've been buying for years. If you've never added up the tonnes, you won't know the number until it lands.

The second is liability. If your supplier can't prove the recycled content of the film you're using, you can't prove it either.

The third is data. EPR runs on weights by material. Many sites know what they paid per pack and nothing about grams per pack, so the report is a guess.

What questions should you ask suppliers, and what records should you keep?

Ask each supplier four things. What's the recycled content of this product, by weight? Can you give me written evidence of that? Are you registered for Plastic Packaging Tax, and is it in my price? What does each item weigh, and what is it made from?

Keep the answers, the dates and the name of whoever gave them. File them with the spec sheet and declaration of compliance for each product.

For EPR, keep a simple record per product of material, weight per unit and units bought. Review it every time the spec changes, and at least once a year. Your buyer or technical lead should own it, with operations signing off the weights.

Weigh a sample of each item rather than trusting the label. A roll that's lighter than it says changes your tonnage, and your bill.

Frequently asked questions

Do I pay Plastic Packaging Tax on pallet wrap?

The tax is charged on the manufacturer or importer, not the buyer, and only where the wrap contains less than 30% recycled plastic. It's usually built into the price you pay.

How much recycled content avoids the tax?

At least 30% recycled plastic by weight. Below that, tax applies at £228.82 a tonne from 1 April 2026.

Am I a large or small producer for EPR?

Large means over £2m turnover and over 50 tonnes of packaging. Small means £1m to £2m turnover with over 25 tonnes, or over £1m with 25 to 50 tonnes. Under £1m or under 25 tonnes, there's no obligation.

Are Year 2 EPR fees final?

We couldn't find confirmed Year 2 fees when we checked in October 2026. The published figures are illustrative and could change.

Let us show you what's in your packaging

We'll look at what you're buying with you: wrap, film, bags and gloves. We'll show you what's in it and what evidence you should hold for recycled content and weight.

It's part of our free site check. We walk the site with your operations team for about 30 minutes and send a written report. No contract. We arrange testing only where it's needed.

We actively source as much recyclable product as we can. Every client gets their own login with every spec sheet, certificate and declaration of compliance for what they buy from us.

Email sales@kptrading.uk or call 020 4576 5500.

Sources

GOV.UK Plastic Packaging Tax: https://www.gov.uk/government/publications/introduction-of-plastic-packaging-tax/plastic-packaging-tax

GOV.UK Check if you need to register for Plastic Packaging Tax: https://www.gov.uk/guidance/check-if-you-need-to-register-for-plastic-packaging-tax

GOV.UK Secondary liability and joint and several liability notices for Plastic Packaging Tax: https://www.gov.uk/guidance/secondary-liability-and-assessment-notices-and-joint-and-several-liability-notices-for-plastic-packaging-tax

GOV.UK EPR for packaging: who is affected and what to do: https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do

GOV.UK EPR for packaging 2025 base fees: https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-2025-base-fees/extended-producer-responsibility-for-packaging-2025-base-fees

GOV.UK Year 2 illustrative waste disposal fees: https://www.gov.uk/government/publications/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging

Illustrative figures are labelled in the text. Images are illustrative.