Preparing for pEPR year 1 invoicing: key information for liable producers
Source: gov.uk (2025-09-08)

Essential steps and guidance to help producers prepare for invoicing and payments now available.

In October 2025, obligated producers under the UK’s Extended Producer Responsibility for packaging (pEPR) scheme will receive their first invoices for the assessment year from 1st April 2025 to 31st March 2026. A producer’s share of disposal costs will be calculated based on their submitted 2024 packaging data. To support producers in meeting their pEPR requirements, outlined below are the key steps and essential information needed to prepare for the invoicing and payment process.

PackUK, as the pEPR Scheme Administrator delivering on behalf of the UK’s four nations, is responsible for setting EPR fee rates for household packaging materials, invoicing and collecting fees from obligated producers, and issuing payments to local authorities to cover household packaging waste management costs.

Payment process overview: what to expect

Obligated producers will receive their annual invoice - also referred to as a Notice of Liability (NoL) - in October 2025.

The size of your liability will be based on the data you have submitted, and calculated based on data submitted by all known producers at the time of issue. Fees may be subject to change following an end of year recalculation when additional data has been submitted. Not all producers will receive an updated invoice at year end. Adjustments may only apply to producers who resubmit their data and where such resubmissions result in material changes to a producer’s obligation.

Accessing your invoice (Notice of Liability)

The Notice of Liability (invoice) will be accessible through the Report Packaging Data (RPD) system in October 2025.

When an invoice is issued, PackUK will email the primary contact listed on your RPD account. The primary contact is the main point of contact for anything related to the service. The email will confirm what is owed and that the invoice is available on the Report Packaging Data (RPD) service.

If the primary contact cannot log into RPD, they must notify an:

approved user

delegated user

secondary contact

Only RPD users can administer the account, download the invoice, and view past payments. If there are finance and accounts department personnel who will require access but are not already RPD users, an Approved User will need to add them to the account or download and forward the relevant documents. Please note that the customer service team are only permitted to discuss account details and payment queries with the Primary Contacts and Approved Users listed on the RPD file as caller authentication will be in place.

For users who have not logged into the RPD system recently, it is recommended that you log in before October to check your details. This will help you avoid delays when accessing your account.

For subsidiaries that are part of a group registration, the holding company will receive the invoice and is responsible for payment on behalf of its subsidiaries. Subsidiaries that registered independently will be liable for their own fees.

PackUK will provide further detailed instructions on the online process by late September.

Payment options and requirements

When you receive the notification that your invoice is ready, it must either be paid in full 50 days from the date of the issuance of the invoice on the first page OR you may choose to pay in accordance with the pre-defined four-instalment payment plan that that you must enable manually either by setting up a Direct Debit instruction or choosing a payment plan to be paid. Failure to do so may result in penalty charges and legal action to recover this debt. Overpayments will be held on account and will go towards future fees.

Payment can be made with one of the following methods:
- direct debit - set-up through Stripe
- bank transfer - each producer will receive a unique virtual Stripe account number (VBAN) to pay directly into
- credit card – paid by card using Stripe
- standing order - set up and paid via a business bank account
Please note: SWIFT payments cannot be accepted as Stripe is not configured for this method.

Payments are managed by Stripe, a globally regulated Payment Service Provider that securely processes electronic payments on behalf of Defra and PackUK. When you make a payment, funds are initially received and processed by Stripe before being transferred to Defra’s accounts.

Statutory debt conditions

As pEPR Notices of Liability are issued under The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (https://www.legislation.gov.uk/uksi/2024/1332/contents) and classed as statutory or regulatory debt, this means:
- PackUK is not classified as a supplier or vendor
- penalty fees for late payment will not be delayed
- no purchase orders will be provided or quoted on invoices
- VAT numbers will not be quoted, as PackUK is a government body
- payments cannot be delayed due to use of a supplier portal or requests for purchase orders, supplier framework documentation, or anti-money laundering documentation
Late payments

If you are late paying, you may be liable to pay a variable monetary penalty of (whichever is greater):
- 20% of your unpaid disposal and administration fees; or
- 5% of your UK turnover if registered as single organisation / 2% of your UK group turnover if registered as a group.
The cost breakdown you will see on the invoice

The latest published base fees include additional costs linked to Extended Producer Responsibility (EPR) for packaging. Including them in the published base fees makes it easier for liable producers to calculate their fees before the receive their invoice. Your invoice will show these costs listed out separately for transparency. The additional costs are:
- scheme administration costs
- public information disposal costs
- impairment provision for bad debt
Scheme administration costs

PackUK works out your share of the scheme administration costs by dividing the total amount for the 2025-26 Assessment Year across all liable producers in the same proportion as disposal fees are distributed across liable producers in that year, in accordance with regulation 65 (https://www.legislation.gov.uk/uksi/2024/1332/regulation/65).

Public information disposal costs

The costs PackUK expects to incur each year to provide public information about:
- the re-use of packaging
- how packaging waste is managed
- how to prevent packaging litter
PackUK works out your share of public information disposal costs by dividing the total amount for the 2025-26 Assessment Year across all liable producers in the same proportion as tonnages of packaging waste are distributed across liable producers in that year, in accordance with regulation 63 (https://www.legislation.gov.uk/uksi/2024/1332/regulation/63).

Impairment provision for bad debt

The impairment fee is an additional sum added to liable producers’ fees to reflect the estimated amount of fees PackUK will be unable to collect in relation to Year 1 Notice of Liabilities. The percentage applied is updated each year, in accordance with regulation 66 (https://www.legislation.gov.uk/uksi/2024/1332/regulation/66), taking into account the actual level of uncollectable debt.

Recalculations

PackUK can recalculate the fees you owe if there is likely to be a material difference from the original calculation.

This can happen if:
- new or further information becomes available to PackUK
- PackUK finds an error in the original calculation
- it is likely that the total disposal or scheme administration fees collected will differ from the overall costs
- the outcome of a complaint or appeal by a producer or local authority requires it
- PackUK reasonably believes a material difference is likely for any other reason
Recalculations can be made:
- at any time during the assessment year, an ‘interim recalculation’
- after the end of the assessment year, a ‘year-end recalculation’
PackUK can decide whether and when to carry out a recalculation, unless a recalculation is required following an appeal decision.

If there are material changes to your level of liability, PackUK will send a revised notice explaining the new amount and how it was calculated. Please refer to Chapter 5 of the Regulations for more information.

Help with fee enquiries

If you think you may not be able to pay or want to change a payment plan, contact the helpdesk.

As a producer who is liable to pay a disposal fee or scheme administration costs for an assessment year you will be able to dispute your fee if you consider that:
- you are not liable to pay a disposal fee or administration fee
- the amount you have been assessed to pay has been miscalculated
To dispute your fee, you must first make a complaint. You can do this in the service by raising a complaint or by contacting the helpdesk. If your complaint is not upheld, you are entitled to appeal the decision under regulation 105.

Preparation checklist

✓ ensure RPD account contact details and email addresses are up to date

✓ add finance personnel requiring payment administration access to the account

✓ review submitted 2024 tonnages and calculate estimated fees using published material rates

✓ prepare internal processes for statutory debt payment without traditional supplier documentation

Payment security and scam prevention

To reduce the risk of scams, PackUK will never send producers a payment link via email. Producers are reminded they should log into their Report Producer Data (RPD) account to view and arrange payment of their Notice of Liability/Invoice. Please also be mindful that scammers may attempt to contact you by phone or letter to perpetrate fraud.

If you wish to raise any concerns, check the validity of any communications, or think you may have been a victim of a scam (or an attempted scam) please report this to the EPR support desk.

Further support and contact information

For all queries, including requests for a change in payment plan or alternative communications formats, please contact the Extended Producer Responsibility helpdesk via the channels below.
- telephone: xx-xxxx-xxxx (Monday to Friday, 8am to 4.30pm)
- email: xxx@xxx.xx (mailto:xxx@xxx.xx)
Producer cooperation in ensuring timely and accurate payments and data submissions is appreciated. PackUK is committed to delivering a system that offers value for money while supporting efficient recycling and disposal services, and these submissions are essential to the effective operation of the scheme.

Please prepare accordingly and contact the helpdesk with any questions before invoicing begins in October.