PackUK Share Key Information on Preparing for Year 1 pEPR Invoicing

Producers liable under Extended Producer Responsibility for Packaging (pEPR) will begin receiving their first invoices – known as Notices of Liability or NoLs – from October 2025.

These invoices will cover Year 1 of pEPR, running from 1 April 2025 to 31 March 2026, and will be based on packaging data reported for the 2024 calendar year.

PackUK state the size of a producer’s liability will be based on the packaging data they have submitted and calculated against data from all known producers at the time invoices are issued.

Invoices will be issued through the Report Packaging Data (RPD) online system, and only Primary Contacts and Approved Users will be able to view and manage them. Producers are being urged to check their access now to avoid issues later, as the system will be the sole route to download and process payment details.

It was confirmed invoices may be recalculated if materially new or corrected data is submitted later in the year, but the expectation is for producers to pay the initial invoices in full and on time. Late or missed payments may incur statutory penalties, set at either 20% of the outstanding amount, or a percentage of company turnover.

PackUK highlighted that producers should ensure finance teams are fully briefed on the process and that systems are in place to manage payments promptly once invoices are received. This first year of invoicing will be closely monitored, and Defra has made clear that compliance will be enforced to ensure a fair system for all obligated producers.

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