What are EPR fees?
Producer Responsibility Organisations (PROs): an entity that manages producers’ legal obligations for packaging waste by collecting fees and coordinating recycling and recovery on their behalf.
How EPR contributions are calculated: typically by weight, material type, and quantity of packaging placed on the market, with fee tariffs set by your PRO.
Key point: EPR fees are not a tax; they’re compliance contributions to finance collection, sorting, and recycling.
What is the Plastic Packaging Tax?
- Nature: an indirect tax collected by national tax authorities to discourage virgin plastics and encourage recycled content.
- UK rate: £223.69 per tonne for plastic packaging with <30% recycled content (from 1 April 2025).
- Spain rate: €0.45 per kg of non-recycled plastic in non-reusable plastic packaging.
- Invoicing note: UK—no legal requirement to show PPT on invoices (businesses often include a statement for transparency). Spain—manufacturers pass the tax on in the first domestic sale and must show tax amount and kg of non-recycled plastic on the invoice; in other domestic supplies, the purchaser can request invoice/certificate disclosure.
EPR vs Plastic Packaging Tax — the core differences
| Aspect | EPR Fee | Plastic Packaging Tax (UK & Spain) |
|---|---|---|
| Nature | Compliance contribution to PROs to fund collection, sorting, and recycling. | Government indirect tax on plastic packaging with low/no recycled content. |
| Who pays | Producers/first importers/brand owners → payment to PROs. | Manufacturers/importers → payment to HMRC (UK) / AEAT (Spain). |
| Pass-through | Usually treated as compliance cost; may be priced in but not a consumption tax. | Typically passed down the supply chain; UK — no mandatory invoice line; Spain — invoice disclosure required in specified cases. |
| Purpose | Finance waste-management infrastructure and meet packaging laws. | Shift behaviour, increase recycled content, and raise fiscal revenue. |
| Data focus | Pack weights, materials, formats, placed-on-market volumes. | Recycled content %, net kg of non-recycled plastic, tax calculation. |
Why organisations struggle
- Two regimes, two owners: EPR sits with regulatory/CSR teams; plastic tax sits with finance/tax.
- Different bases: EPR fees use material & weight tariffs; plastic tax uses non-recycled plastic or recycled-content thresholds.
- Data silos: packaging specs live in procurement/design; tax records live in finance.
- Cashflow hit: plastic tax is a fiscal liability; EPR is a budgeted compliance spend.
How to manage both—without duplication
- Map the scope & owners: document who does EPR vs who does plastic tax; align deadlines.
- Create one packaging dataset: a single source of truth for weights, materials, formats, recycled content %.
- Build a shared workflow: give finance access to packaging specs; give compliance access to tax records to prevent mismatches.
- Optimise design choices: increase recycled content to lower tax exposure; choose formats that reduce EPR fees.
- Automate evidence: store supplier recycled-content certificates and PRO confirmations alongside SKU data.
Key takeaways
- EPR ≠ tax; plastic tax is an indirect tax.
- Treat them as parallel obligations with shared data, not the same process.
- Be explicit on invoice practices: UK—transparency statement recommended; Spain—invoice disclosure rules apply in defined cases.
Quick FAQ
Is EPR an indirect tax?
No. It’s a compliance contribution paid to PROs to finance collection and recycling.
Is Plastic Packaging Tax an indirect tax?
Yes. It’s a government tax on plastic packaging with low or no recycled content.
Do I need to show plastic tax on invoices?
UK: no mandatory invoice line (a statement is commonly provided). Spain: manufacturers must show the tax and non-recycled kg on the first domestic sale invoice; others disclose on invoice/certificate if the buyer requests.