Managing EPR Costs for Glass Packaging: Practical Solutions for UK Food Producers

Obligated UK producers can reduce their Extended Producer Responsibility (EPR) bill on glass packaging by managing three levers: the recyclability rating of each pack, the weight of the glass, and the accuracy of the tonnage data they submit. EPR has been live since October 2025, and from Year 2 the fee a producer pays depends on how their packaging is rated: Green, Amber, or Red under the Recyclability Assessment Methodology. Green-rated glass costs £185 per tonne while Red-rated glass costs £245 per tonne and rises on a confirmed multiplier every year. This guide sets out the practical moves a procurement or operations team can make now to cut total EPR liability, aimed at the large producers who carry the obligation. For the line-by-line cost of EPR, PRN, and PPT together, see our companion article on what the three regulations actually cost your glass packaging in 2026.

Who Carries the EPR Obligation

EPR fees apply to large producers: organisations with annual turnover above £2 million that handle more than 50 tonnes of packaging in a year. If your business meets both thresholds, you pay the full cost of collecting, sorting, and recycling the household packaging you place on the UK market. That cost used to sit with local authorities. It now sits with you.

The scheme is administered by PackUK under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332). Glass household containers are explicitly in scope, and the definition is broad: bottles sold to bars and restaurants count, not only retail packaging, because glass is treated as likely to enter the municipal waste stream regardless of where it is sold. For a procurement team, that means the obligation reaches across every SKU and every channel, so the mitigation work has to be systematic rather than pack by pack.

The first invoices were issued from October 2025, based on 2024 packaging data. The important shift for 2026 is that the flat per-tonne fee has been replaced by a modulated structure that rewards recyclable packaging and penalises the rest. That change is what turns EPR from a fixed cost into something a producer can actively manage.

What EPR Costs Glass in 2026

Fees are charged per tonne, which puts a direct weight penalty on glass. The confirmed Year 1 base fee was £192 per tonne. For Year 2, covering packaging placed on the market in 2025, PackUK has published illustrative fees on a three-tier structure:

Most producers will pay the Green rate, because most standard glass already qualifies. The per-unit cost that flows from these rates, and how it compares with plastic, is covered in the Jars & Bottles guide to what food producers pay per bottle or jar. The point for a cost-reduction strategy is narrower: the gap between Green and Red is where the money is, and that gap widens every year.

The Red Multiplier Is the Cost You Control

A £60 difference per tonne between Green and Red looks modest on a single order. It does not stay at £60. The Red fee escalates on a confirmed multiplier schedule: Red packaging pays 1.6 times the base rate in Year 3 (2027/28) and 2.0 times in Year 4 (2028/29).

On current base rates, a Red-rated pack in 2028/29 would cost roughly £410 per tonne against about £185 for Green. A producer carrying a Red-rated SKU today is accumulating that exposure every year the pack stays on the market. For a procurement team, the rating of each pack is the single most valuable variable in the whole scheme, because it is fixable and the saving compounds. Everything below is ordered by how much liability it removes.

Solution 1: Move Every Pack to a Green Rating

Most standard glass bottles and jars are already Green-rated. Two stages of the assessment affect the rating today under RAM version 1.1, the version that applies for the whole of the 2026 reporting year. It is worth being precise about both, because some guidance still in circulation is out of date.

At collection stage, standard glass bottles and jars are widely collected at kerbside and pass this stage automatically. Four categories do not: mirrored glass, heat-resistant or lead glass, decorative glass (etched, frosted, or similarly treated), and glass designed so that product residue cannot be removed by the consumer — PackUK’s own examples are nail polish bottles and concealer jars. These are rated Red unless a valid take-back scheme applies, in which case they are capped at Amber rather than reaching Green.

At application stage, three things push a pack to Amber: ceramic swing-stoppers; non-glass attachments that cannot be separated by hand, such as pumps or dispensers; and colour outside the four accepted options of clear (flint), green, blue, or amber (brown). Two points worth flagging, because they run against commonly repeated guidance:

• Metal attachments such as screw-top skirts and collars are explicitly excluded from the non-separable-attachment rule. A standard metal closure does not affect the rating, regardless of whether it separates by hand.
• Blue is one of the four accepted colours today, not just the three most often cited. Only colours outside all four – and any bespoke or frosted finish – create risk.

One widely repeated rule no longer applies at all: label or sleeve coverage above 60% of the surface was removed from the methodology when version 1.1 was published in April 2025. If your specification process still screens for this, it is not necessary.

Audit your range against the collection and application criteria above and you will find your Amber exposure sits in a small number of decorative, treated, or genuinely non-standard-colour SKUs. Those are the packs to redesign first. The Recyclability Assessment Methodology guidance sets out how each feature is assessed, and British Glass publishes a RAM guidance document specific to glass packaging that explains what qualifies a pack as Green. A supplier can use both to tell you in advance which tier a proposed design will land in before you commit to tooling.

Looking Ahead: RAM 2027

PackUK published RAM 2027 on 1 July 2026. It applies from the 2027 reporting year (packaging placed on the market from 1 January 2027, first reports due 1 October 2027) and changes nothing about the 2026 criteria described above, which continue to apply for the whole of the current reporting year. Two changes are worth planning for now.

Colour stops being a factor at all, not just a wider list of accepted colours. Today, four specific colours are accepted: clear (flint), green, blue, and amber (brown). Anything else  black, opaque white, pink, purple, or any other bespoke tint or frosted finish – risks Amber. Under the RAM 2027 materials guidance, any soda-lime-silica glass rates Green regardless of colour, provided it is commonly collected at kerbside. Only glass that was never really the same material – lead crystal, heat-resistant types such as borosilicate, ceramic – stays automatically Red. In short, colour drops out of the assessment entirely rather than moving to a longer accepted list.

A new universal check appears in its place. RAM 2027 rates any packaging Red, in any material category, if it contains PFAS above set thresholds, other substances of concern, or non-compliant food contact materials. This does not exist under the current 2026 methodology. So if you use or are planning to use in 2027 printed, enamelled, or coated glass, the practical step is a written declaration from your ink, coating, or decoration supplier covering three things: 

• PFAS content below the RAM 2027 thresholds (1 part per million total, or 25 parts per billion on food contact packaging)
• compliance with the relevant UK REACH, SVHC, POPs, biocides, and CLP limits
• confirmation that any food-contact surface meets current UK food contact materials legislation

If a supplier cannot provide this today, ask what reformulation or testing would close the gap, and build that lead time into your supplier reviews now rather than discovering it when reporting opens on 1 October 2027. Keep the declaration on file: RAM evidence does not need to be submitted to PackUK proactively, but it must be retained for seven years and produced if a regulator asks for it.

Solution 2: Take Weight Out of Green-Rated Glass

Once a pack is Green, weight is the remaining lever, because the fee is charged per tonne. Lightweight glass technology can reduce container weight by 15% to 30% without compromising strength or shelf appeal, and every gram removed comes straight off the EPR calculation as well as off transport cost.

The practical route is to start with your highest-volume formats, where a small per-unit weight saving multiplies across the largest number of units. Ask your supplier for a lightweighting analysis on those formats, prototype and test for breakage rates in transit before committing, and calculate the EPR and freight saving against any mould or transition cost. Lightweighting has limits: some premium formats need to retain weight for shelf presence, and carbonated products have pressure constraints that set a floor on wall thickness. Within those limits, weight reduction is a permanent annual saving rather than a one-off.

Solution 3: Consolidate Formats and Buy in Volume

Two commercial moves reduce total EPR liability without touching pack design. The first is format rationalisation. Every low-volume SKU carries its own tonnage, its own rating risk, and its own administrative overhead. Consolidating pack sizes concentrates volume into fewer, more efficient formats and reduces the total weight of glass you place on the market.

The second is volume purchasing. Buying glass in larger quantities lowers the per-unit cost, which gives you margin headroom to absorb the EPR fee without a price rise. Our online shop Jars & Bottles supplies wholesale glass packaging with transparent bulk pricing, so a procurement team can model the volume discount directly against the EPR increase on a given SKU and see where the two net off.

Solution 4: Fix Your Data Before It Fixes Your Bill

EPR fees are calculated from the tonnage and rating data you submit, so an error in the data is an error in the bill. Two data tasks protect against overpaying.

Check your tonnage figures against the amendment deadlines. Year 1 fees are based on 2024 data, and corrections have a closing window. The amendment window for first-half 2026 data closes on 1 October 2026, and corrections after that date will not reduce your obligation. Submit nation data accurately as well: large producers must report which UK nation their packaging is placed in across England, Scotland, Wales, and Northern Ireland, and this is a mandatory 2026 reporting obligation. Getting the split right matters because disposal costs vary by nation.

Data accuracy is the least visible lever and often the fastest saving, because it requires no design change and no supplier switch. It is a matter of assigning clear internal ownership for EPR reporting and meeting the deadlines.

Solution 5: Recover the Cost Through Positioning

The moves above reduce the fee. Positioning recovers what remains. Glass is remelted indefinitely without losing quality, it does not leach into food or drink, and it holds the strongest sustainability perception of any mainstream packaging material. Those are verifiable attributes rather than marketing claims, and they support a premium price that carries the residual EPR cost.

The strategy is to concentrate glass on the product lines where the customer already expects and will pay for premium, sustainable packaging, and to communicate the material’s recyclability plainly on pack and in trade conversations. British Glass publishes industry data and guidance that a marketing team can draw on to substantiate those claims. Framed correctly, EPR compliance becomes part of a credible environmental position rather than a cost buried in the margin.

A Procurement Checklist for the Rest of 2026

1. Audit every SKU against the current RAM 1.1 criteria: decorative or treated glass, non-separable non-metal attachments, and colour outside clear, green, blue, or amber. Ignore the 60% label coverage rule, which no longer applies. Redesign the Amber packs first.
2. Request a lightweighting analysis on your three highest-volume Green-rated formats.
3. Rationalise low-volume SKUs and consolidate pack sizes where the range allows.
4. Model bulk-purchase discounts against the EPR fee on your top SKUs to find where volume pricing offsets the increase.
5. Check your EPR tonnage data and correct it before the 1 October 2026 amendment deadline.
6. Confirm your UK nation reporting split is accurate for the 2026 obligation.
7. Assign a named internal owner for EPR monitoring, and subscribe to PackUK and Defra updates so rate and rule changes reach you in time to plan.
8. Ask suppliers to confirm inks, coatings, and decorative finishes meet the RAM 2027 PFAS and substances-of-concern thresholds, ahead of the 1 October 2027 deadline.

Producers who treat EPR as a fixed cost will pay the fee in full and pass it on. Producers who work the levers above will pay less, protect margin, and turn a compliance obligation into a point of difference.

Frequently Asked Questions

How can a producer reduce EPR fees on glass packaging? The largest saving comes from making sure every pack is rated Green under the Recyclability Assessment Methodology, because Red-rated glass costs more per tonne and that gap widens each year. After rating, the next lever is weight: lightweighting a Green-rated pack by 15% to 30% cuts the fee proportionally. Format consolidation, volume purchasing, and accurate tonnage data reduce liability further.

What is the difference between Green and Red EPR fees for glass in 2026? For Year 2, illustrative fees are £185 per tonne for Green-rated glass, £205 for Amber, and £245 for Red. Red-rated packaging also escalates on a confirmed schedule to 1.6 times the base rate in Year 3 and 2.0 times in Year 4, so the cost of a Red rating grows every year it is left unfixed.

What makes glass packaging Amber-rated under EPR in 2026? Under RAM version 1.1, the version that applies for the whole of 2026, the main causes are decorative or treated glass such as mirrored, heat-resistant, or frosted finishes; non-metal attachments that cannot be separated by hand, such as ceramic swing-stoppers, pumps, or dispensers; and colour outside the four accepted options of clear, green, blue, and amber. Metal closures such as screw-top skirts and collars are explicitly excluded from the attachment rule and do not affect the rating. A rule some guidance still cites, covering label or sleeve coverage above 60% of the surface, was removed from the methodology in April 2025 and no longer applies. Each remaining risk is fixable with a design change, and a supplier can confirm the likely rating before you commit to a new pack.

Who has to pay EPR fees on glass packaging? EPR fees apply to large producers: businesses with UK turnover above £2 million that place more than 50 tonnes of packaging on the market per year. Both thresholds must be met. Smaller businesses may still have registration and data-reporting duties but do not pay the disposal fee.

Does lightweighting glass actually reduce EPR costs? Yes. EPR fees are charged per tonne, so reducing the weight of a bottle or jar reduces the fee by the same proportion. Lightweight glass can be 15% to 30% lighter without losing strength or shelf appeal. The saving is largest on high-volume formats, where a small per-unit weight reduction multiplies across the most units.

When is the deadline to correct EPR tonnage data for 2026? The amendment window for first-half 2026 data closes on 1 October 2026. Corrections submitted after that date will not reduce the obligation, so tonnage and rating data should be checked well before the deadline.

Does RAM 2027 change what EPR fees a producer pays now? No. RAM 2027, published by PackUK on 1 July 2026, applies only to packaging placed on the market from 1 January 2027, with first reports due 1 October 2027. Producers use RAM version 1.1 — the version behind current Green, Amber, and Red rates — for the 2026 reporting year. Two changes matter for planning: colour stops being a factor for standard soda-lime-silica glass from 2027, and a new universal check rates any packaging Red if it contains PFAS or other substances of concern above set thresholds, regardless of material.

Sources

1. Defra — Extended producer responsibility for packaging: recycling obligations and waste disposal fees
2. Defra / PackUK — Year 2 illustrative waste disposal fees: Extended producer responsibility for packaging
3. Defra — Recyclability Assessment Methodology: assessing materials
4. Legislation.gov.uk — The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332)
5. British Glass — Industry data and guidance
6. British Glass — RAM guidance document for glass packaging
7. PackUK — RAM 2027: overview, published 1 July 2026.
8. PackUK — RAM 2027 materials assessment guidance, published 1 July 2026.