---
title: EPR Fees Force Brands to Recalculate Packaging Costs
lang: en
source: https://mindsprt.dev/en/knowledge/uk-pepr-packaging-recyclability-gap/
---

# EPR Fees Force Brands to Recalculate Packaging Costs

*Industry Insights · 6 min read · 2026-07-16*

> UK Defra data makes one thing clear: sustainable packaging has moved onto the cost sheet, not just brand statements.
This article breaks down, from a print consultant’s perspective, how brands and small to mid-sized printers should audit SKUs, classify packaging, and prioritize redesigns

**Quick answer:** UK Defra data makes one thing clear: sustainable packaging has moved onto the cost sheet, not just brand statements

## Overview

Among the 11,701 UK packaging producers required to report, 89% are still supplying non-recyclable, hard-to-recycle, or mixed-rated packaging. pEPR fees will push the cost pressure of Red and Amber packaging directly back to brands. MINDS recommends that brands begin with an SKU-based redesign method: audit every item, mark each as Red, Amber, or Green, then move high-volume, high-visibility, and high-fee-risk packaging into the first redesign wave.

## Where Are 89% of UK Packaging Businesses Still Stuck?

ThePackagingPortal cited UK Defra data showing that, among 11,701 packaging producers with reporting obligations, 89% still supply non-recyclable, hard-to-recycle, or mixed-rated packaging. For anyone working in packaging, that number is hard to ignore because it shows that real-world transition is moving much more slowly than brand messaging.

・14% of producers use only Red rated packaging, meaning roughly 1 in every 7 still relies entirely on materials that are difficult or problematic to recycle.

・1% of producers use only Amber rated packaging, a category that still faces clear recycling challenges.

・75% of producers use a mix of Red, Amber, and Green packaging, which means most companies have started changing, but have not completed the transition.

・Only 10% of producers have fully shifted to Green packaging.

What I see in print and packaging projects is very similar: brands often start by changing carton copy, color, and certification marks, while the truly difficult changes involve composite films, mixed-material laminates, special coatings, spot embellishments, inserts, and label adhesives. These are usually hidden inside cost sheets. Once EPR fees arrive, finance teams begin pulling them out one by one for review.

EPR, or Extended Producer Responsibility, means that brands or producers are responsible for recycling, processing, or related costs tied to packaging waste after products are sold. The harder a package is to recycle, the higher its future fees and reporting pressure are likely to be.

## How Will pEPR Fees Force Packaging Redesigns?

The pressure from pEPR will not stay inside legal or compliance teams. It will eventually appear in three places: the packaging BOM, the SKU margin sheet, and the annual redesign plan. The UK data, with 14% fully Red and 75% mixed-rated packaging, shows that most brands are not missing an environmental slogan. They are missing a packaging list that maps directly to costs.

The problem with Red packaging is usually not a single material alone, but the structure: paper-plastic composites, metallized films, dark plastics, labels that are hard to separate, special coatings, or multilayer laminates. These designs may look strong on shelf, but often create problems at the recycling end. pEPR fee design turns that recycling problem into a brand cost.

Amber packaging sits in an awkward middle ground. It looks somewhat better than Red, but may still not enter a stable recycling stream. If a brand simply replaces Red with Amber, it may reduce short-term pressure, but could still be caught by new fee rates later. This is where I would caution procurement teams: do not mistake “less bad” for “already safe.”

For Taiwanese brands, the UK is not distant news. Exports, OEM work, cross-border e-commerce, and international retail listings all bring this logic into the supply chain. When clients ask for packaging data, recycling labels, material breakdowns, or carbon-related documents, a small or mid-sized printer that cannot answer may be excluded even if its quote is cheaper.

## How Should Taiwanese Brands Audit SKUs?

I would start with SKUs, not slogans, because SKUs connect directly to packaging materials, printing methods, purchase volume, channel visibility, and fee risk. Defra’s UK data classifies 11,701 producers into Red, Amber, and Green. Taiwanese brands can apply the same logic internally before regulations arrive at their door.

MINDS’ three print-readiness checkpoints can be applied to EPR redesign preparation this way:

・① Materials checkpoint: list each SKU’s outer box, insert, pouch material, label, sealing sticker, and cushioning material, then mark paper, plastic, aluminum film, composites, coatings, or varnishes.

・② Structure checkpoint: check whether consumers can disassemble, clean, and sort the packaging; whether different materials are permanently bonded; and whether labels interfere with recycling the main packaging material.

・③ Channel checkpoint: rank items by annual sales volume, return rate, exposure position, and export market, then redesign high-volume and high-risk SKUs first.

When it comes to prioritization, I usually do not ask brands to change everything at once, because that can quickly get stuck in inventory, molds, color management, and procurement contracts. For the first wave, three packaging types are enough: high-volume regular items, channel-priority items, and export or cross-border items. These three categories are most likely to affect fees, reputation, and customer complaints at the same time.

If a brand already has mid- to high-end fully custom commercial printing needs, it can combine packaging audits with MINDS printing services for proofing, material substitution, and post-press evaluation. Use small-batch redesigns first to validate paper stocks, films, coatings, and color variation. Do not place an entire year’s packaging inventory behind an untested plan.

## How Should Printers and Designers Respond to This Demand?

For small and mid-sized printers, the first thing to improve is not a polished presentation deck, but the material language inside quotations. When clients ask, “Can this be recycled?” sales teams cannot simply answer, “It’s paper, so probably.” They need to be able to discuss the main material, coating, lamination, varnish, adhesive, and post-press process. That is how printers will be able to capture redesign projects after pEPR.

Designers also need to adjust the order of ideation. In the past, packaging often chased visual memorability first, then looked for materials to match. Now, for high-risk items, the recycling path needs to be considered in the layout and structure from the start. Removing one composite layer or one hard-to-separate material can sometimes be worth more than adding another visual effect.

From recent brand projects, I can clearly feel procurement teams asking more detailed questions: Can matte film be replaced with water-based varnish? Can a plastic insert become paper? Can the label adhesive be changed to a solution that interferes less with recycling? These questions used to be treated as bonus points. Now they are entering procurement comparisons.

For SaaS and AI application teams, the most practical entry point is not writing sustainability copy for brands. It is turning packaging data into searchable, comparable, and traceable SKU records. Each item can be tied to material, structure, supplier, version, annual usage, preliminary Green/Amber/Red assessment, and redesign status. Tools like this are what can actually enter print and procurement workflows.

## Key Takeaways

・EPR fees will turn “hard to recycle” from a brand image issue into an SKU cost issue.

・The fact that 89% still use Red, Amber, or mixed-rated packaging shows that most companies need a redesign sequence, not more promotional language.

・Packaging redesigns should begin with three checkpoints: materials, structure, and channels. Start with high-volume, high-visibility, and high-regulatory-risk items.

・Printers need to explain materials and post-press processes clearly before they can qualify for the next wave of sustainable packaging redesigns.

・For designers, removing one hard-to-separate material layer may have more commercial value than adding another visual effect.

## Further Thinking

For Taiwanese print manufacturers, now is the time to turn material data, post-press limitations, and alternative options into an internal knowledge base. For designers, proposals should explain the recycling path alongside the visual solution. For AI and SaaS teams, the opportunity lies in SKU-level packaging data management, not broad sustainability talk. For brand clients, the MINDS Knowledge Academy consulting team can help classify packaging items first, then work with print and design teams to create executable redesign batches.

## Further Reading

・[UK Defra data reveals that nearly 90% of packaging producers still use non-sustainable materials](https://www.thepackagingportal.com/industry-news/new-defra-data-reveals-nine-out-of-ten-packaging-producers-using-non-sustainable-materials/)

## FAQ

### Does the fact that 89% of UK packaging businesses use hard-to-recycle materials matter to Taiwanese brands?

Yes, especially for brands involved in exports, OEM work, cross-border e-commerce, and international retail channels. Fee systems such as the UK’s pEPR will make channels pay closer attention to packaging materials, recycling classifications, and the completeness of supplier data.

### Will pEPR increase brand packaging costs?

The direction of pEPR is to make hard-to-recycle materials carry higher fees. UK data already points out that Red and Amber packaging face operational cost and reputational risks. If brands do not redesign, cost pressure may become more visible year by year.

### Which packaging should brands redesign first?

Start with SKUs that have high usage, high visibility, and high regulatory risk, such as regular bestsellers, channel-priority products, and export items. Lower-volume or seasonal packaging can be handled gradually afterward.

### How should printers respond to clients’ sustainable packaging needs?

Printers should clearly list the main material, coating, lamination, varnish, adhesive, and post-press processes, while preparing alternative materials and proofing options so clients can evaluate cost, quality, and recycling risk together.

### Does Green packaging mean there is no risk at all?

Green packaging means it is more likely to enter a recycling path, but brands still need to consider local recycling capacity, consumer sorting behavior, and the actual packaging structure. A single label is not enough to judge whether a package is safe.


---

> HTML version: https://mindsprt.dev/en/knowledge/uk-pepr-packaging-recyclability-gap/
> MINDS — 麥思印刷整合有限公司 · https://mindsprt.dev