Packaging used to be somebody else's decision. Marketing wanted shelf stand-out, NPD wanted the barrier properties, procurement wanted the price. Technical checked the declarations, signed it off and moved on to the next thing.
That's over. Your packaging specification now carries a per-tonne cost; the size of that cost depends on how recyclable the pack is, and the person who has to evidence the classification works in your technical team.
Since April 2025, packaging producers have funded the full net cost of managing household packaging waste. In the first assessment year the fees were flat, charged per tonne by material: £423 for plastic, £266 for aluminium, £259 for steel, £196 for paper and card, £192 for glass. For a site putting a few hundred tonnes of packaging on the market, that's a cost line that didn't exist two years ago.
From the 2026-27 assessment year the flat rate has gone and the disposal fee element is modulated by recyclability, graded through the Recyclability Assessment Methodology on a traffic-light system. PackUK's illustrative figures for plastic put green at around £415 a tonne, amber at £455 and red at £545.
The gap between those three numbers is the part to pay attention to, because it widens. The modulation factor applied to red-rated packaging is 1.2 for 2026-27, 1.6 for 2027-28 and 2.0 for 2028-29. By the end of the decade, the disposal fee element on a red-rated pack will be double the amber equivalent.
A multi-layer film that scores red carries a recurring cost, and that cost rises every year you keep it. Reformulating the pack is now a commercial decision with a number attached, and the technical team is the only part of the business that can tell you what the number is.
The scale of it shows in what manufacturers are asking government for. In the FDF's Q2 2026 survey, 56% wanted the EPR scheme subsidised to reduce producer fees, putting it level with energy costs and behind only minimum wage increases on the list of asks.
None of this arrives as a neat project. It arrives as reporting.
You're submitting packaging data in kilograms, split by material, by whether it's primary, secondary, tertiary or shipment, and by whether it's likely to become household or non-household waste. Classify primary or shipment packaging as non-household and you need evidence, kept for seven years. Large producers have had to report plastic as rigid or flexible since January 2025. The RAM guidance is reviewed and reissued annually, so the version you assessed against last year isn't the one you'll use next year.
Then there are the dates. Packaging placed on the market in the first half of 2026 was due to be reported by 1 October. The second half is due by 1 April 2027, and PackUK intends to issue the initial 2026-27 notice of liability by the end of November. Somebody on your site owns those deadlines. On a lot of sites, nobody has formally been given them.
All four UK nations are due to start operating a deposit return scheme on 1 October 2027, with a 20p deposit on single-use drinks containers between 150ml and 3 litres made from PET, steel or aluminium. Glass is excluded in England, Scotland and Northern Ireland, with Wales running a transition for glass to October 2031.
For a drinks manufacturer that's artwork, barcoding, registration of every in-scope container, and changes to how product is tracked through the line. For everyone else it's a reminder that the regulatory pipeline isn't slowing down.
The obvious response to a per-tonne fee is to use less material, and plenty of sites are down-gauging film, reducing board grades and taking weight out of trays. It works. It also lands squarely on the technical team.
Thinner film changes seal integrity. Lighter board changes drop test performance and pallet stability. A material switch can change shelf life, and shelf life means challenge testing, trials, retailer approval and a revised specification. Nobody has ever taken weight out of a pack without the line telling them about it within a fortnight.
So every gramme saved on the EPR return has to be bought with technical work, and that work needs people who can do it properly rather than quickly.
The Packaging Technologist role has changed most. It used to support NPD. It now owns a compliance position that carries direct cost consequences, and that calls for someone who can talk about material science, retailer specification and regulatory reporting in the same meeting.
Technical Managers are picking up data ownership they weren't recruited for. New titles are appearing on org charts, from Packaging Compliance Lead to Sustainability Manager, and the candidate pool behind them is thin because the combination of skills is recent. People who've run a full pEPR reporting cycle in a food business are, for now, a small group.
Decide who owns packaging data, properly, with it written into a job description. On too many sites the task has drifted to whoever had capacity, which works until that person leaves.
Bring packaging technical into concept stage rather than sign-off. A pack that's assessed for recyclability when it's being designed costs far less than one reformulated after the fee notice arrives.
And if you're short-handed through a reporting cycle, interim technical support is a sensible way to get through it without pulling your Technical Manager off everything else for a month.
We recruit Packaging Technologists, Technical Managers, Quality Managers and sustainability specialists into food and drink manufacturing, and it's the only sector we work in. If the packaging workload has outgrown the team carrying it, we'll tell you what the market looks like for the skills you need.
Call the team on 0161 399 1575 or email info@truenorthtalent.co.uk.
Sources
Food and Drink Federation, Extended Producer Responsibility – an overview – fdf.org.uk
Food and Drink Federation, State of Industry Report Q2 2026 – fdf.org.uk
House of Commons Library, Deposit return schemes (CBP-10453) and Packaging extended producer responsibility (CBP-10352) – commonslibrary.parliament.uk
Use this form to send us a message, and we'll get back to you shortly.
Explore our latest market insights on all things food and drink manufacturing.
Packaging used to be somebody else's decision. Marketing wanted shelf stand-out, NPD wanted the barrier properties, procurement wanted the price. Technical checked the declarations, signed it off and moved on to the next thing. That's over. Your packaging specification now carries a per-tonne cost; the size of that cost depends on how recyclable the pack is, and the person who has to evidence the classification works in your technical team.
The new robotic palletiser gets signed off in February and runs beautifully until a Sunday night in May, when it throws a fault nobody on site has seen before. Your shift engineer works through the obvious checks. The OEM's helpline opens at nine on Monday. Two lines are backed up until then, and there's a delivery vehicle booked for six in the morning. That's the gap between bringing in automation and being able to run it. It's also the reason a lot of food manufacturers are getting less out of their capital spend than the business case promised.
Your Engineering Manager resigns on a Friday afternoon. By Monday you've briefed three agencies. By Wednesday you're looking at twenty-two CVs, and eighteen of them have never set foot in a food environment. You've now lost most of a week and you're no closer to filling the role. The line is still running, the planned maintenance schedule is already slipping, and your Operations Manager has picked up a second job on top of their own. This is the point where the difference between a generalist agency and a specialist recruiter stops being a procurement preference and starts costing you output.