Fibre-based composite pEPR fees may have been overinflated by £5m
Producers of fibre-based composite (FBC) packaging like liquid cartons, sandwich wrappers, and ready meal containers may have been significantly overcharged by the packaging Extended Producer Responsibility (pEPR) scheme.
A recent report commissioned by ACE UK and review led by our packaging experts Dr Liz Wood, Charlotte Davies, and Alex Hilton, found that:
The £461 per tonne pEPR fee charged by PackUK for FBCs has been incorrectly calculated, with the true figure being £34/t lower on a conservative analysis of available data sources, and potentially as high as £92/t.
Applied to the fees paid by brands for FBC materials last year, this suggests that fees could have been overpaid by between £5m and £13m.
This report identifies several areas where current assumptions materially overstate the cost burden applied to FBC packaging. The most significant issue relates to the cost to local authorities of collecting packaging for recycling or disposal, with the scheme currently charging £509/t to collect FBC compared with just £264/t for paper and card, despite the two having very similar properties.
The collection figure
The collection figure is calculated based on the volume of packaging rather than its weight and may overstate the amount of space taken up by FBCs in two ways.
Firstly, the model appears to assume that more of the FBC category is made of liquid cartons than is actually the case, which has a significant impact as cartons take up more space in collection vehicles.
Secondly, it assumes that non-liquid FBCs have the same bulk density as the card category, which is predominantly made up of bulky corrugated cardboard boxes.
By using available data on both the liquid/non-liquid split, and the estimated bulk density of non-liquid FBCs, our experts found that the collection costs applied may have been significantly overstated. Amending the model would bring the collection costs for FBCs closer to those of paper and card, and deliver a significant reduction in the fee per tonne of between £34/t and £92/t.
Key drivers of the overcharge
The current fee of £461/tonne appears to be disproportionately high for fibre-based composites.
The review identifies two key drivers of overcharge. The bulk density assumed for non-liquid cartons is based on corrugated cardboard rather than the lighter retail packaging formats that dominate kerbside FBC waste.
The market split between liquid and non-liquid cartons also overstates the share of low-density liquid cartons. Since recyclate collection costs represent nearly two-thirds of FBC waste-management costs and are apportioned by volume, both factors inflate the volume allocated to FBC waste and therefore the proportion of collection cost it bears.
Combined, data revisions could reduce the disposal fee by approximately 8%. The review also highlights widespread misreporting of FBCs as paper and card and demonstrates the influence this had on disposal fee cost for 2025.
Additional findings
In addition to the immediate concerns around collection costs, the review also highlights several other issues which may further overinflate the FBC fee and recommends further research and analysis of data.
It sets out that collection costs currently assume that packages like liquid cartons are never compacted during the process either by consumers or collection vehicles. This would significantly overstate the volume that these materials occupy in the waste stream, as cartons take up far more space when they have not been flattened. Evidence suggests that there is an element of compaction by both consumers and vehicles, and the report finds that this could further reduce fees by around 10%. However, this would require further research and a change in methodology by PackUK.
Finally, the report explores concerns around the misreporting of FBCs as paper and card, with many packages in the two categories being very similar in appearance and performance. Although early statistical analysis from our Beyondly data suggests misreporting alone may not yet explain broader paper and card tonnage changes, the report concluded that even modest levels of misclassification could materially affect the fee.
Ben Powell, Head of External Affairs, ACE UK commented: “This report shines a light on the true extent of the artificially high pEPR disposal fees charged to producers of FBC packaging, including liquid cartons.
It is clearly implausible to charge nearly twice as much for local authorities to collect a tonne of FBC than a tonne of paper and card. The impact of this discrepancy alone seems to have cost brands millions of pounds more than it should have done last year.
As the pEPR system beds in, we know that the data and assumptions used will continue to improve, leading to a more accurate cost being applied to every package on the market. We were really pleased to work with Beyondly on this excellent report, which offers robust recommendations backed up by evidence.
We look forward to continuing to work constructively with PackUK to ensure disposal fees are fair for all packaging types, which is essential if we want to make our shared sustainability goals a reality.”
About ACE UK
The Alliance for Beverage Cartons and the Environment (ACE) UK represents Tetra Pak, Elopak and SIG Group, the leading manufacturers of liquid cartons for the UK and European markets. ACE UK’s objective is to promote liquid cartons as a renewable and low carbon packaging choice and delivers environmental initiatives in the UK on behalf of members, including running the industry’s liquid carton recycling programme.
