Understanding the UK EPR Scheme for Glass Packaging: A Complete Guide for Food & Drink Businesses

UK EPR fees cost 4-11p per glass bottle. Understand the 2025 weight-based system, business impact, and practical strategies to manage costs while staying sustainable.

What You'll Learn

• How the UK's Extended Producer Responsibility (EPR) scheme works and who it affects
• The actual per-unit costs for glass packaging under the 2025-2026 fee structure
• Why weight-based fees create higher costs for glass compared to other materials
• Business impact across different sectors and company sizes
• Practical strategies to manage EPR costs whilst maintaining sustainable packaging choices

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility is a regulatory framework that shifts the financial burden of packaging waste collection and management from local authorities to the businesses that place packaging onto the UK market.

The UK's EPR scheme, administered by PackUK, officially launched in October 2025 when the first invoices were issued to producers. The scheme targets "large producers"—organisations with annual turnover exceeding £2 million that handle more than 50 tonnes of packaging annually.¹

Key dates:

• October 2025: First invoices issued (based on 2024 packaging data)
• November 2025: First payment deadline (or start of quarterly instalments)
• 2026-2027: Planned introduction of eco-modulated fees

The scheme is expected to generate approximately £1.5 billion in its first year. Revenue is allocated to PackUK's administrative costs and payments to local authorities for household packaging waste collection. However, there is no legal requirement mandating how councils spend these funds, which has become a point of industry concern.³

The British Retail Consortium has campaigned for legal ringfencing to ensure the £1.5 billion is spent specifically on recycling infrastructure rather than general council budgets. The Office for Budget Responsibility has classified EPR as a tax in its fiscal assessments.²

Understanding Your EPR Costs: Calculations and Examples

The Fee Structure (2025-2026)

The initial fee structure uses a flat rate per tonne of material placed on the market:

Source: DEFRA, June 2025¹

At first glance, glass appears to have one of the lowest per-tonne rates. However, this metric can be misleading when applied to real-world purchasing decisions.

How to Calculate Your Per-Unit Cost

The formula is straightforward: (weight in kg) × (fee per kg) = EPR cost per unit

Businesses don't purchase packaging by the tonne—they order by the unit (bottles, jars, containers). This means the actual cost per item varies significantly based on packaging weight.

Example calculation for a 500g glass bottle:

• Weight: 0.5 kg
• Fee rate: £192 per tonne = £0.192 per kg
• Cost per bottle: 0.5 × £0.192 = 9.6 pence

Real-World Cost Comparison

Here's what EPR fees look like for common packaging formats:

Calculations based on official DEFRA rates and typical packaging weights⁵

Manufacturers and distributors including Pattesons Glass and Hildon have confirmed these cost ranges. When factoring in supply chain margins and VAT, the retail price impact may be approximately double the raw EPR fee.⁶

Why the Current Structure Creates Challenges for Glass

The cost comparison above reveals a fundamental issue: whilst plastic carries a higher per-tonne rate (£423 vs £192), the per-unit cost for businesses is substantially lower due to weight differences.

The core challenge is that EPR fees are based on weight, not environmental impact.

Glass packaging is heavier than plastic, but it's also infinitely recyclable, chemically stable, and suitable for closed-loop reuse systems. Under the 2025-2026 fee structure, these circular credentials don't reduce costs or provide any financial advantage.

Three Key Policy Features Affecting Glass

1. No Recyclability Incentive in Year 1

The planned "eco-modulation" system would apply fee adjustments based on packaging recyclability ratings. A highly recyclable, clear glass bottle rated "Green" would pay less than a difficult-to-recycle coated bottle of the same weight.

This system has been delayed until the 2026-2027 scheme year at the earliest.¹⁰ For all of 2025-2026, fees are flat and based purely on weight. A 100% recyclable glass bottle incurs exactly the same fee as an unrecyclable glass container of identical weight.

2. Temporary Exemptions for Competing Materials

Single-use drinks containers made from PET plastic and aluminium (150ml–3L capacity) are currently exempt from EPR fees. These materials were intended to be covered by the planned Deposit Return Scheme (DRS), which would handle collection and recycling through consumer deposits.

The DRS has been delayed until October 2027 at the earliest. Glass beverage containers are excluded from the DRS scope in England and therefore remain fully liable for EPR fees.⁹

This creates a two-year minimum window where producers using plastic bottles or aluminium cans for beverages pay no EPR fees, whilst direct competitors using glass bottles pay 4-11p per unit.

Randy Burns, Chief Sustainability Officer at O-I Glass, stated: "Glass is still carrying more than its fair share of the system's cost—while aluminium and PET get a free pass... We believe in a level playing field. One where recyclability is rewarded."⁹

3. Weight-Based Calculation

Glass packaging typically weighs significantly more than plastic alternatives due to material density and the structural requirements for bottle production. This physical reality, combined with per-tonne pricing, creates higher absolute costs regardless of environmental performance.

Nick Kirk, Technical Director at British Glass, highlighted this structural concern: "Brands don't buy a tonne of packaging. They buy a million bottles, or a million cartons. They always buy in quantity, so EPR should be calculated on that basis."⁴

Glass recycles at approximately 76% in the UK—higher than plastic.² It can be remelted indefinitely without losing quality or purity. It doesn't leach chemicals into food or drink. Yet under the current calculation method, these advantages don't translate into lower per-unit costs for businesses.

Business Impact Across Sectors

Large Producers and Retailers

The British Retail Consortium reports that over 80% of EPR costs are expected to be passed through supply chains to consumers. The Bank of England has estimated the policy will contribute approximately 0.5% to food inflation.³

For major retailers and beverage producers operating on tight margins, even small per-unit increases can materially impact profitability. Pricing strategies, supplier negotiations, and product portfolios are all affected by the new cost structure.

Small and Medium Enterprises (SMEs)

SMEs in the food and drink sector face particular challenges under the EPR framework. These businesses typically operate with thinner profit margins and less capital to absorb sudden cost increases or invest in packaging redesign.

Case Study: Isle of Wight Distillery

The distillery had invested in creating reusable glass bottles designed for closed-loop collection. Compliance and Sustainability Manager Charity Parker noted: "We have created glass bottles to be reused and to go back into the circular economy. It would actually be cheaper to put our liquid into plastic bottles."⁷

This example illustrates how the current fee structure can create financial pressure on businesses that have specifically chosen glass for its circular economy potential.

Private Label Supply Arrangements

The EPR regulations define the "first brand owner" who supplies goods as the responsible party for fee payment. In private label arrangements, this definition can create unexpected liability.

If an SME producer supplies a product to a retailer carrying any of the producer's own branding (even as a secondary mark), the producer, not the retailer, may be liable for EPR fees on all packaging.⁸

Many smaller suppliers had anticipated that retailer partners would carry primary responsibility for private label products. This legal structure has created unexpected financial exposure for some businesses.

Note: Liability definitions can vary by specific contract terms. Always consult a legal expert regarding your specific supply agreements.

Hospitality Sector

Pubs, restaurants, and hotels face a particular challenge. These businesses pay for commercial waste collection services to dispose of glass bottles and other packaging. Simultaneously, they receive the EPR fee embedded in their wholesale purchasing costs for packaged beverages.²

This creates a dual-cost scenario where the same packaging is effectively paid for twice - once through the supply price (which includes the producer's EPR cost) and once through commercial waste contracts.

Industry groups have raised this issue with DEFRA. The definition of "household packaging" in the regulations is broad enough to capture primary packaging sold in hospitality venues, despite these businesses having separate commercial waste arrangements.

How Industry is Responding to EPR Challenges

Trade Body Statements

Multiple industry organisations have issued formal responses to the EPR fee structure:

Joint Industry Statement: British Glass, the Wine and Spirit Trade Association (WSTA), and the Scotch Whisky Association released a coordinated statement expressing concern about "disproportionately high fees for glass."⁴

Miles Beale, CEO of WSTA, noted that the UK's EPR fee for glass is approximately 8 times higher than Germany's equivalent scheme - a comparison that has featured prominently in industry discussions about international competitiveness.⁴

British Retail Consortium (BRC): The BRC has focused its response on two primary concerns:

• The inflation impact on consumers, with the Bank of England confirming a 0.5% contribution to food inflation
• The lack of legal ringfencing for EPR revenue, campaigning for mandatory requirements that funds be spent on recycling infrastructure rather than general council budgets³

Glass Manufacturer Responses: A spokesperson for glass manufacturer Encirc stated: "The Government needs to hit the pause button... Sadly, the Government's pricing structure has not taken into account that glass is far more sustainable than plastic and weighs considerably more."⁵

Policy Design Discussion Points

The industry response has highlighted several structural questions about the EPR scheme's design:

Weight vs. Performance Metrics: The disconnect between tonnage-based fees and unit-based purchasing has been a consistent theme. Some stakeholders have referenced alternative models used in certain EU member states that incorporate performance-based adjustments or unit-based calculations.¹¹

Revenue Accountability: Without legal ringfencing, industry participants have expressed concern about whether the £1.5 billion raised will be fully directed toward recycling infrastructure improvements. The Office for Budget Responsibility's classification of EPR as a tax has reinforced these concerns.²

Timing of Eco-Modulation: The delay in implementing recyclability-based adjustments means the scheme's first year provides no financial incentive for choosing more recyclable packaging designs within the same material category. Industry voices have noted this eliminates a core intended feature of the policy.¹⁰

Material Exemptions During Transition: The temporary exemption for PET and aluminium drinks containers during the 2025-2027 DRS development period has been characterized by some stakeholders as a market distortion that creates unequal competitive conditions.⁹

Green Alliance, in written evidence to Parliament, cautioned that policy design focused narrowly on specific materials "risks shifting environmental harm to other materials" rather than addressing single-use packaging systems more broadly.¹¹

Practical Strategies for Managing EPR Costs

While policy questions continue to be debated, businesses using glass packaging need practical strategies now. The approaches below can help manage EPR costs whilst maintaining commitment to sustainable packaging materials.

1. Packaging Weight Optimisation

Lightweighting involves reducing packaging weight whilst maintaining structural integrity, product protection, and brand presentation.

Weight reduction targets of 10-15% are often technically achievable without compromising bottle performance. Premium spirits brands including Johnnie Walker and Champagne Telmont have successfully implemented lightweight designs (180g and 800g bottles respectively) that maintain shelf presence whilst reducing material costs, transport emissions, and EPR liability.⁵

Implementation steps:

• Request lightweighting analysis from your glass packaging supplier
• Prototype and test designs for breakage rates during transport and handling
• Assess consumer perception through small-scale trials
• Calculate EPR savings against any tooling, mould, or transition costs
• Consider phased rollout starting with highest-volume SKUs

Realistic expectations: Not all bottle formats can be significantly lightweighted. Premium positioning may require maintaining certain weight standards. Technical constraints around pressure (for carbonated beverages) or shape complexity limit some applications.

2. Supply Chain and Sourcing Review

Local sourcing can reduce transport costs and carbon footprint. For some businesses, it may also support development of regional closed-loop collection models.

Reuse systems eliminate per-unit EPR costs for participating businesses, though current regulations do not yet provide specific financial incentives for glass reuse models.¹⁰ B2B applications (such as refillable containers for hospitality) may offer the most immediate opportunities.

Implementation steps:

• Map your current glass packaging supply chain and identify transport costs
• Evaluate UK-based suppliers for key product lines
• Investigate regional collection and reuse opportunities (particularly for B2B channels)
• Monitor policy updates on potential closed-loop system incentives
• Calculate break-even points for any infrastructure investment in reuse systems

3. Pricing and Margin Strategy

Cost pass-through analysis helps determine which products can absorb EPR costs within existing margins and which require price adjustments.

SKU rationalisation may involve adjusting pack sizes, consolidating low-volume variants, or repositioning premium lines where consumers demonstrate higher price tolerance.

Implementation steps:

• Calculate EPR impact per SKU as both absolute cost and percentage of wholesale/retail price
• Model price elasticity for different product categories and customer segments
• Identify which product lines have margin capacity to absorb costs
• Test small price adjustments on limited SKUs before broader rollout
• Consider value messaging that supports premium positioning

Pricing context: The BRC estimates that 80% of EPR costs will be passed to consumers.³ Transparent communication about regulatory cost increases, framed within broader sustainability commitments, may support pricing adjustments.

4. Consumer Communication

Consumer research indicates strong positive associations with glass packaging. A 2025 McKinsey survey found that "glass and paper-based packaging are seen as the most sustainable materials" and that consumers "value packaging solutions that align with circularity principles."¹²

Transparency about packaging costs can support pricing decisions, particularly when framed within sustainability commitments that align with customer values.

Implementation steps:

• Develop clear messaging about packaging material choices and their environmental benefits
• Highlight glass's infinite recyclability and closed-loop potential
• Frame any necessary price adjustments within broader sustainability commitments
• Use on-pack and digital marketing to reinforce quality and environmental positioning
• Consider educational content about EPR compliance as demonstration of transparency

5. Compliance Management and Policy Monitoring

Stay informed on regulatory developments. The EPR framework is expected to evolve over its initial years:

• Eco-modulation fee structures (targeted for 2026-2027 introduction)
• Deposit Return Scheme implementation timeline and scope
• Potential amendments for closed-loop system incentives
• Any changes to material exemptions or calculation methodologies

Implementation steps:

• Assign clear internal responsibility for EPR compliance monitoring
• Consider joining relevant trade associations (British Glass, sector-specific groups)
• Subscribe to DEFRA and PackUK policy update channels
• Budget for potential fee structure changes in 2026-2027
• Participate in consultation processes when opportunities arise

Timeline: Expected Policy Changes Through 2027

Understanding the EPR scheme's development roadmap helps with strategic planning:

2026-2027 Scheme Year

• Eco-modulated fees scheduled for introduction: Fee adjustments based on packaging recyclability ratings. Highly recyclable formats rated "Green" would pay reduced fees; difficult-to-recycle formats rated "Red" would pay premiums. This would create the first financial incentive within material categories for circular design choices.¹⁰
• Potential amendments to current exemptions: Industry pressure may drive changes to material exemptions or calculation methods before eco-modulation launches.

October 2027

• Deposit Return Scheme (DRS) anticipated launch: If implemented as currently scoped, DRS would cover PET plastic and aluminium drinks containers (150ml-3L). This should end the current exemption for these materials from EPR fees.⁹
• Glass remains outside DRS scope in England: Current policy excludes glass beverage containers from DRS, meaning EPR remains the primary compliance mechanism for glass.

Ongoing Considerations

• Closed-loop system incentives: November 2025 amendments introduced offsets for closed-loop systems, but currently only for food-grade plastics. Industry groups continue to advocate for equivalent treatment for glass reuse models.¹⁰
• Revenue ringfencing: The BRC and other trade bodies continue to campaign for legal requirements that EPR funds be spent specifically on recycling infrastructure.³

What to Monitor:

• DEFRA consultation processes and policy announcements
• PackUK guidance updates on eco-modulation methodology
• Trade association briefings on DRS implementation timeline
• Any pilot programmes for closed-loop glass collection systems

Need Support With Glass Packaging Compliance?

At Jars & Bottles, we understand the EPR compliance landscape and work with UK food and drink businesses to identify wholesale glass packaging solutions that balance cost management with quality and sustainability goals.

Technical guidance: Our team can help you evaluate lightweighting possibilities, calculate EPR impacts for your product range, and identify packaging solutions that align with your cost and sustainability objectives.

Contact us to discuss your specific packaging requirements and EPR cost optimisation strategies.

References

1. DEFRA – Extended Producer Responsibility for Packaging: 2025 base fees and implementation guidance, June 2025. 
2. UK Parliament Library – Impact of extended producer responsibility for packaging on glass packaging producers, 2025. 
3. British Retail Consortium (BRC) – Retail Sector Response to EPR reforms, packaging tax impact on consumers, and ringfencing campaign, October 2025. 
4. Wine and Spirit Trade Association (WSTA), British Glass, Scotch Whisky Association – Joint industry statement on EPR glass fees, September-October 2025. 
5. Drinks Retailing News – EPR Base Fees labelled ambiguous and counterproductive
6. Pattesons Glass – Managing EPR Costs for Glass Packaging: manufacturer and brand perspectives, 2025. 
7. BBC News – Glass levy dampens producers' spirits, 2025. 
8. Mills Reeve – New EPR rules and private label liability for SMEs, 2025. 
9. DEFRA Environment – Introducing the deposit return scheme for drinks containers
10. Clarity Environmental – Understanding EPR Modulated Fees and delayed implementation timeline, 2025. 
11. Green Alliance – Written evidence to UK Parliament on EPR design and material impacts (PWC0014), 2025. 

McKinsey & Company – Sustainability in packaging 2025: Inside the minds of global consumers, 2025.