UK packaging EPR in 2027-28: where paper cushioning sits on the fee scale
Red-rated household packaging pays 1.6 times the base fee in 2027-28. How RAM rates paper cushioning, what turns paper red, and what to sort out in 2027.
From April 2027, red-rated packaging in the UK pays 1.6 times the base disposal fee. A year later it pays double.
UK packaging EPR charges disposal fees on household packaging, and since 2026-27 those fees depend on a red, amber or green recyclability rating. Red pays 1.2 times the amber fee in 2026-27, 1.6 times in 2027-28 and 2.0 times in 2028-29, and green gets a discount. Plain kraft paper cushioning, such as honeycomb paper wrap, is assessed as paper and board and can rate green, if the producer holds the evidence. Shredded strips narrower than 40 mm, paper with more than 5% plastic, and anything carrying more than 1 ppm PFAS land somewhere else.
Checked against official sources on 28 October 2026.
A UK packaging distributor sells our honeycomb rolls under its own brand and product codes, so these fees sit on our own customers' desks every year. I am a manufacturer, not a compliance scheme. Who registers and who reports is covered in our post on packaging EPR registration in the EU and UK. This post is only about the fee scale.
Which packaging pays the disposal fee at all?
Household packaging. GOV.UK's page on recycling obligations and waste disposal fees (updated 7 April 2026) says large producers pay disposal fees only on packaging classed as household, commonly binned packaging and household glass drinks containers.
Here is the part online sellers miss. The guidance on how to assess household and non-household packaging (updated 5 August 2025) says shipment packaging must be classed as household unless specific conditions are met. The main one is that you supply it to a business or public institution that is the end user. You need evidence, such as contracts, sales records or customer declarations, and you keep it for at least 7 years.
| Where the wrap ends up | Class | Disposal fee |
|---|---|---|
| In a parcel to a consumer | Household | Yes, modulated by the rating |
| In a delivery to a business end user, with evidence | Non-household | No disposal fee |
| In a delivery to a business, with no evidence | Household | Yes |
So the same roll of wrap can pay a fee in one packing room and none in the next.
What changes in 2027-28?
The multiplier on red goes up, and the gap between red and green gets wider.
PackUK's disposal fees modulation statement sets red at 1.2 times the amber fee in 2026-27, 1.6 times in 2027-28 and 2.0 times in 2028-29. The extra money from red forms a pot that pays for an equal percentage discount on every tonne of green. Amber does not change, and the total of all household disposal fees does not go up.
The only per-tonne figures so far are the Year 2 illustrative fees (GOV.UK, updated 19 December 2025, rounded to the nearest £5):
| Material | Green | Amber | Red |
|---|---|---|---|
| Paper and board | £190 | £210 | £250 |
| Fibre-based composite | £475 | £525 | £630 |
| Plastic | £415 | £455 | £545 |
They are illustrative, and the green figure was marked provisional. No Year 3 fee figures had been published by 28 October 2026. I will not guess them.
Which year's packaging pays the 1.6 times?
This is the point I would put in front of a finance team.
The fees page says the data you report for one year sets the fees for the next. The modulation statement says the first modulated fees, for 2026-27, use packaging supplied in 2025.
On the same pattern, the 1.6 times in 2027-28 is charged on packaging supplied in 2026, rated with RAM version 1.1. Packaging you supply during 2027 is rated with RAM 2027 and, on that pattern, billed in 2028-29, the year of the 2.0 times.
So this year's packing already decided the 1.6. The choices you make for 2027 meet the 2.0.
For 2027 data, the RAM guidance gives two deadlines: January to June data by 1 October 2027, and July to December data by 1 April 2028.
Where does paper cushioning land under RAM 2027?
The RAM 2027 materials assessment guidance (GOV.UK, updated 20 August 2026) checks paper and board at four stages: collection, sorting, reprocessing and application. An item is green only if it is green at every stage. Some things make it red at once, and so does having no evidence.
| Paper cushioning | Likely rating | The RAM 2027 rule behind it |
|---|---|---|
| Plain, unprinted kraft honeycomb wrap | Green, if the evidence is held | Commonly collected, no non-paper content, pieces far larger than 40 mm |
| Coloured honeycomb wrap | The colour alone does not change it | Dyes and pigments count as paper content |
| Shredded or crinkle strips narrower than 40 mm | Red, as I read the size rule | Sorting needs at least 40 mm in at least 2 dimensions |
| Paper with more than 5% plastic by mass | Assessed as fibre-based composite | A different and higher fee line |
| Paper with more than 10% non-paper content | Amber, and red above 15% | Reprocessing stage |
| Greaseproof, siliconised or waxed paper | Red | Collection stage |
| Padded envelopes lined with polyethylene | Red | Collection stage |
| Bagasse, straw or other non-wood fibre | Amber | Application stage |
| Any item with more than 1 ppm total PFAS | Red | Automatic red, before any stage |
| Anything with no evidence for amber or green | Red | Missing evidence |
The PFAS line surprises people, so we wrote a separate post on PFAS in paper packaging.
The size rule is the one I would check first. Honeycomb wrap comes out of a parcel as a sheet many times bigger than 40 mm in both directions. A strip of shredded paper is long, but narrow.
I cannot rate your packaging for you. The rating belongs to the producer who reports it, on the evidence in its own file.
What the fee scale means per roll and per parcel
These sums use the Year 2 illustrative paper fees, because no Year 3 figures exist yet. Read them as a sense of scale, not a forecast.
Our 390 mm x 250 m roll at 80 GSM carries 0.39 x 250 x 80 = 7,800 g of paper, before the core. So a tonne of paper is about 128 of those rolls.
- At £190 a tonne (green), that roll's paper carries about £1.48 of disposal fee.
- At £210 (amber), about £1.64.
- At £250 (red), about £1.95.
Now per parcel. Say each parcel uses 1.5 m of flat 380 mm wrap at 80 GSM. That is 0.38 x 1.5 x 80 = 45.6 g, so 1,000 parcels use 45.6 kg. At the same three fees that is about £8.66, £9.58 and £11.40 per thousand parcels.
On plain paper, the gap between green and red is a couple of pounds per thousand parcels. The real jump comes when paper stops counting as paper. The illustrative fibre-based composite fee was more than double the paper fee at every rating.
Weight drives every one of these numbers. Our guide to honeycomb paper consumption shows how to measure what each order really uses.
Do you need to print a recyclability label?
No. GOV.UK's RAM supplementary guidance says there are no legal obligations for recyclability labelling under packaging EPR, and the RAM 2027 overview says the ratings are not related to any label on the pack. Ratings go to the regulator in your data, not onto the carton.
So do not reprint your boxes for 2027 because of EPR. Spend the money on evidence instead.
What to do before 1 January 2027
- Split your packaging flows into consumer parcels and business deliveries. For the business ones, collect evidence that the customer is the end user, and plan to keep it for 7 years.
- List every cushioning material you use, with the weight per parcel.
- Ask each supplier for the composition by weight: paper content, any plastic, other non-paper content, fibre type, inks if printed, and PFAS evidence.
- Measure any shredded fill against the 40 mm rule.
- Move red-rated items off your packing line during 2027, because on the pattern above, 2027 packaging meets the 2.0 times.
- Watch PackUK's operational plan and notices for the final Year 2 fees and the first Year 3 figures.
Where we fit
Our honeycomb paper wrap is plain kraft paper with cuts in it, and about 99% of what we ship is 100% recycled fibre, sold with the FSC Recycled 100% claim on the invoice under licence FSC-C193292. We check the roll weight of every lot we make, so we can give your compliance team real weights, not estimates.
Tell us your role and your packaging flows through our contact page. We will send composition and weights in the format your scheme asks for, and tell you plainly which documents we hold and which we do not.
Questions buyers ask
Is honeycomb paper wrap green under RAM?
Plain, unprinted kraft honeycomb wrap meets the paper and board criteria that usually cause trouble. It can be rated green if the producer holds the evidence for each stage. The rating is the producer's call, made on its own file, not a supplier's promise.
Do I pay disposal fees on paper wrap in B2B shipments?
Not if the shipment goes to a business that is the end user and you hold evidence of it, such as contracts or customer declarations. Without that evidence, GOV.UK says shipment packaging must be treated as household.
Does coloured honeycomb paper lose the green rating?
Not because of the colour. RAM 2027 counts dyes and pigments as part of the paper. Printing is a different matter, because inks not made in line with the European Printing Ink Association (EuPIA) rules make an item red.
