How Your Load Security Choices Affect Your EPR Bill
If your packaging spend has crept up without a matching rise in shipment volume, Extended Producer Responsibility (EPR) fees are very likely part of the story. Since January 2025, UK producers have carried the full net cost of managing household packaging waste, and from 2026 those fees are increasingly shaped by recyclability, not just tonnage.
For courier and postal operators, that shift raises a question few teams have asked out loud: does the material you use to secure a load count towards that bill? And if it does, can you reduce your exposure without weakening the load security your drivers, warehouses and customers depend on?
This guide breaks down how EPR fees are actually calculated, where load restraint materials fit into that calculation, and how to bring your EPR exposure down without introducing the damage, claims and delay costs that come from under-securing a load.
What EPR Actually Charges You For
Extended Producer Responsibility for packaging makes businesses financially responsible for packaging they place on the UK market, from production through to disposal. The regulations took effect on 1 January 2025, and large producers pay fees based on the type, weight and recyclability of packaging they supply.
For 2025-26, fees were flat, charged per tonne of material regardless of design. That changes from 2026: packaging is now assessed under the Recyclability Assessment Methodology (RAM) and given a Red-Amber-Green rating, with fees modulated accordingly. Materials that are harder to recycle attract higher charges, while well-designed, recyclable packaging is rewarded with lower fees.
In short: weight, material type, and how recyclable that material is now directly determines what you pay.
Where Load Security Fits Into the EPR Equation
This is where many logistics and courier operators are caught off guard. EPR doesn’t just apply to the box or envelope a product ships in, it can extend to materials used to protect and stabilise that load in transit, depending on packaging class and how it is supplied.
Is strapping, dunnage or edge protection ‘packaging’ under EPR?
Under the regulations, packaging is assessed by class – primary, secondary, shipment or tertiary – and by material: plastic, paper / card, wood, glass, aluminium and steel. Load restraint products used to secure goods for transport commonly fall into shipment or tertiary packaging categories. If your business is the producer or first UK owner of that packaging (rather than simply the carrier moving someone else’s goods), it’s reportable, and it’s chargeable.
That means the volume and type of dunnage bag, strap or edge protector you specify isn’t just an operational decision anymore – it’s a data point that feeds your EPR return.
Weight, material type and recyclability – what actually moves the fee
Three variables matter the most:
- Weight – heavier materials, or more of them per load, increase the tonnage your fees are calculated against
- Material type – some load security materials (certain composite plastics, mixed materials straps etc) are harder to recycle and score lower under RAM, attracting higher modulated fees from 2026 onward.
- Recyclability design – single material, widely recyclable operations tend to score better than composite or contaminated alternatives.
The Trap of Cutting Packaging to Cut Fees
Faced with a rising EPR line item, the instinctive response is to simply use less material. That instinct is understandable – and it’s also where most operations get into trouble.
Load security materials exist for a reason: to stop product movement, prevent pallet collapse, and absorb the shocks, vibrations and drops that are unavoidable in a courier network. Reduce them past the point of adequacy, and the savings on your EPR bill are quickly outweighed elsewhere.
Industry data consistently shows that under-protected loads are the leading cause of avoidable transit damage, and that cost of a return regularly exceeds the cost of the protective material itself. Cutting load security to save pennies on packaging fees is, in practice, one of the more expensive shortcuts an operations team can take.
How to Cut EPR Exposure Without Cutting Load Security
This is the balance point, and it’s entirely achievable with the right approach.
Right-size before you re-specify
Before changing materials, audit how much load restraint product you’re actually using per shipment against what’s genuinely needed. Oversized or excessive dunnage doesn’t just add EPR-chargeable weight, it also increasing handling and freight costs. Businesses that systematically right-size packaging commonly report meaningful reductions in both material use and damage claims simultaneously; the two goals are not in conflict.
Choose recyclable and mono-material options
Where performance requirements allow, mono-material strapping, recyclable edge protection, and paper-based or recycled-content dunnage bags typically score better under the RAM than composite or mixed-materials equivalents, while still delivering full load restraint performance. This is the single higher-leverage available: it reduces the fee per tonne, not just the tonnage.
Get the data before you decide
You can’t manage what you haven’t measured. A proper packaging audit shows exactly where your EPR exposure is concentrated, and where a material swap or right-sizing exercise will make the biggest different to your bill.
Yes, in many cases. Materials used to secure shipment or tertiary packaging - such as strapping, dunnage bags and edge protection - can fall within EPR reportable packaging classes if your business is the producer or first UK owner of that packaging.
From 2026, fees are modulated using the Recyclability Assessment Methodology (RAM), which gives packaging a Red-Amber-Green rating. Fees are based on material weight, type, and how recyclable the packaging design is.
It can lower the weight-based portion of your fee, but if it increases damage, returns or replacement shipments, the not cost to your business if often higher than the fee saved.
Right-sizing usage and switching to recyclable, mono-material options where performance allows are the two most effective, lowest-risk changes.
Large producers (those with £2 million+ turnover handling more than 50 tonnes of packaging annually) must pay EPR fees. Smaller producers currently have reduced obligations, though this may change as the scheme matures.
Recycled content and improved recyclability generally support a better RAM rating, which can reduce the modulated fees compared with harder-to-recycle composite materials - though the exact discount depends on your PRO and current fee structure.
EPR fees are no longer a background compliant cost – from 2026 they’re directly shaped by the material choices made on your packaging line, including dunnage, edge protection and strapping used to secure every load. Treating load security as untouchable, or treating it as the easiest place to cut corners, both miss the real opportunity: right-sizing usage and choosing recyclable, well-designed materials that protect your loads and your margin at the same time.
If you’re not sure where your EPR exposure is coming from, that’s the price the place to start.