Preparing for pEPR Year 1 Invoicing: What Producers Need to Know

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Dan Pegram

Published: 10/09/2025

From October 2025, obligated producers under the UK’s Extended Producer Responsibility (pEPR) scheme for packaging will receive their first invoices, covering the assessment year from 1 April 2025 to 31 March 2026. This marks a major milestone in the implementation of the new packaging EPR regulations, with costs allocated to businesses based on the packaging data they submitted for 2024.

At Flame UK, we’re here to help producers stay informed and prepared. Below, we’ve summarised the key steps and guidance you need to know about pEPR invoicing, payment, and compliance.

Who is responsible for invoicing?

PackUK, acting as the official Scheme Administrator on behalf of the UK’s four nations, will issue invoices (known as Notices of Liability) and collect fees from producers. These fees are then used to reimburse local authorities for managing household packaging waste.

What to expect from your invoice

Issuing date: October 2025
Basis of calculation: Your invoice is based on your submitted 2024 packaging data and data from all registered producers.
Recalculations: Fees may change later if new information is submitted, errors are found, or appeals are upheld.

Invoices will be available via the Report Packaging Data (RPD) system, and only Primary Contacts and Approved Users will be able to access them. If your finance team needs access, make sure they are added to your account before October.

Payment options and deadlines

Producers must either:

Pay the full amount within 50 days of issue, or
Opt into a four-instalment payment plan via Direct Debit or standing order.

Payments will be processed securely by Stripe, and can be made via:

Direct Debit
Bank transfer (via a unique VBAN)
Credit card
Standing order

⚠️ Note: SWIFT payments are not accepted.

Statutory debt conditions

It’s important to remember that pEPR invoices are classed as statutory debt. This means:

No purchase orders will be issued
VAT numbers will not appear on invoices
Payments cannot be delayed due to internal supplier portal processes
Penalty fees for late payment will apply

Late payment penalties

If payment is late, producers may face significant penalties, including:

20% of unpaid fees, or
5% of UK turnover (2% for group registrations), whichever is greater.

What costs are included?

Your invoice will break down three additional fees on top of disposal costs:

Scheme administration costs – the cost of running the pEPR system.
Public information disposal costs – supporting campaigns on re-use, recycling, and litter prevention.
Impairment provision for bad debt – an added fee to cover unpaid debts from Year 1.

Preparing for October: Your checklist

Check your RPD account details and email addresses are correct
Add finance personnel who need invoice access
Review your 2024 tonnage data and estimate fees using published material rates
Ensure your finance team understands that payments are statutory debt and cannot be delayed by PO or supplier processes

What does this mean for your business?

At Flame UK, we specialise in waste and recycling compliance, helping businesses navigate regulatory changes like packaging EPR. With Year 1 pEPR invoices just around the corner, now is the time to review your packaging data, understand your liability, and prepare your payment processes.

Our team can help you: