The Industry’s Simplest Guide to EPR: What Food Businesses Need to Know for 2026
If your food business requires packaging, you've likely been impacted by Extended Producer Responsibility (EPR), which went into full-force on the 1st of April. This expanded legislation requires once- or twice-yearly reporting, depending on the size of your business, and creates financial incentives for using packaging that is easier to recycle. If your packaging does not comply, you will be hit with a fee, so packaged food business must adapt quickly. EPR has the potential to be a catalyst for a more circular packaging economy.
For food manufacturers and suppliers, packaging has always been a functional necessity: critical for safety, shelf-life, and brand identity. Under the new Extended Producer Responsibility (EPR) legislation, packaging is also becoming a financial and reporting liability – and the impetus for building out a circular economy.
EPR moves the cost of managing packaging waste upstream away from the taxpayer and onto the businesses that put packaging into the market. By penalising difficult-to-recycle materials and rewarding circular ones, the policy is designed to fundamentally change how we design, source, and report on packaging.
Some packaging materials will inevitably be more expensive or logistically complex to swap out than others, so this legislation is also intended to influence the packaging producers, putting pressure on them to increase the availability of easy-to-recycle materials.
With a major reporting deadline just gone (1 April 2026), here is our breakdown of what EPR means for your supply chain and your bottom line.
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Beyond Reporting: The Three Pillars of Impact
EPR is more than just paperwork; it is a fundamental shift in how food supply chains must operate.
1. Financial Impact (Modulated Fees)
From 2026, food businesses with packaged goods will pay modulated fees: you'll pay less for packaging that is easy to recycle and significantly more for packaging that is not. Using the Recyclability Assessment Methodology (RAM), materials are assigned a Red, Amber, or Green rating.
- Green: Widely recycled materials will be rated "Green" and receive a financial discount on EPR fees.
- Red: Materials that are very difficult to recycle will be rated "Red" and will receive a penalty, starting at 20% but increasing steadily up to 100% by 2028.
These fees incentivise sustainable packaging solutions and early action to avoid increased financial burden down the line. For food businesses, this likely means a move away from complex flexibles and multi-material laminates that have historically been the industry standard. Fees that are collected will fund more robust collection and recycling infrastructure.
2. Data Granularity
You can no longer simply report "plastic" or "cardboard." EPR requires granular data on:
- Material weights and types.
- Waste categories (e.g., household vs non-household).
- Nation of sale (where in the UK the packaging is likely to end up).
3. Supply Chain Collaboration
EPR makes packaging a shared priority. Suppliers are being asked for more detailed specifications than ever before, while downstream retailers are looking for "EPR-ready" formats to minimise their own fee exposure.
Measurement as an Action Tool
At Foodsteps, we see EPR as another side of the same coin as Scope 3 reporting. The data you collect for EPR compliance – weights, material types, and recycled content – is the exact same primary data needed for an accurate carbon footprint, gathered and improved over time through collaboration with your supply chain.
By aligning your EPR data collection with your product carbon footprints (PCFs), you can:
- Avoid double-work: Use one high-quality data set for both compliance and sustainability reporting.
- Predict costs: Model how switching to a different material affects both your carbon footprint and your EPR fee liability.
- Drive circularity: Move beyond the idea of "less bad", toward better systems and genuine circularity.
Under EPR there is a double incentive to utilise recyclable materials: reduce your financial liability while simultaneously reducing the impact of your food products in a PCF or customer Scope 3 assessment.
Missed the April Deadline? Two steps to take now.
Step 1: Submit late to avoid 'Red' Defaults. Any packaging not properly assessed by the deadline is automatically classified as the most expensive "Red" category. Submitting corrected data now can prevent escalating penalties.
Step 2: Audit for H2. Large producers should use the current "gap" to audit their 2026 H1 data before the October submission, ensuring material weights and recyclability scores are accurate, helping you avoid overpaying.
Want to find out more about how we turn data into action? Download our Methodology for Scope 3 Assessments.
