A packaging technologist in a UK FMCG business now spends a growing share of their time on recyclability evidence, packaging data and design changes that reduce fees, not only on specifications and line trials. Extended Producer Responsibility (EPR) has turned pack design into a cost line, and that changes how many technologists you need and what they must be able to do.
This article sets out what the official guidance requires, where the extra work lands in a packaging team and how to resource it. It draws on GOV.UK guidance, the House of Commons Library and trade press. Rules and fees are still being finalised, so check PackUK's latest position before you plan.
What UK packaging EPR asks of FMCG producers
According to the House of Commons Library, the UK has operated a revised scheme since April 2025. Producers pay fees based on the amount and type of packaging they supply, and the money funds local authorities to collect, sort, recycle and dispose of household packaging.
The first year used flat base fees that reflect average handling and recycling costs. The Commons Library gives the example of plastic at £423 per tonne against £192 for glass. From the second year, fees are adjusted using a red, amber and green rating. Green packaging attracts lower fees. Red attracts higher ones.
Food Manufacture reports that for 2026/27 amber-rated packaging pays the base fee and red-rated packaging pays a 20% premium. The red multiplier is scheduled to rise to 1.6 times in 2027/28 and 2.0 times in 2028/29. The same article cites analysis showing 61.8% of flexible plastic packaging assessed in 2025 received a red rating. For a food manufacturer with several thousand tonnes of films and pouches, that gap is real money.
Why recyclability ratings land on the packaging technologist's desk
Large producers are legally required to use the Recyclability Assessment Methodology (RAM) to rate the household packaging they supply, and to report the results alongside their other packaging data. GOV.UK says assessments cover household packaging and packaging that commonly ends up in public bins. Reusable and refillable packaging only needs assessing the first time it is supplied.
The test is practical. GOV.UK describes RAM as a way to judge whether packaging can be recycled through every stage of the process using existing infrastructure, at scale. Collection alone is not enough. RAM 2027 was published in July 2026 and applies to packaging supplied in 2027.
That makes the assessment a technical job. Someone has to know the layers, barrier coatings, adhesives, inks, closures and sleeves in each pack, and what changes if one of them is swapped. In most FMCG businesses that person is a packaging technologist or a packaging development manager.
Four rules, four sets of work for packaging teams
EPR is not the only reform in play. The table shows how the main measures reach a packaging team. Dates and rates are from the sources named.
| Measure | What the official position is | Where the work lands in the packaging team |
|---|---|---|
| EPR disposal fees | Modulated by red, amber or green rating from 2026/27. Red pays 1.2 times the amber fee, rising to 2.0 times by 2028/29. | Redesign options, cost-per-tonne modelling and SKU prioritisation. |
| RAM 2027 | Mandatory for large producers. Applies to household packaging supplied in 2027. | Component-level assessments, evidence files, supplier declarations. |
| Plastic Packaging Tax | £228.82 per tonne from 1 April 2026 on plastic components with under 30% recycled content (GOV.UK). | Recycled-content specifications and supplier evidence. This is a separate test from RAM. |
| Deposit return scheme | Due to start on 1 October 2027 in all parts of the UK, with a 20p deposit on in-scope drinks containers (House of Commons Library). | Container registration, labelling and specification changes for drinks brands. |
| Data accuracy | PackUK set 1 September 2026 as the last date to resubmit 2025 data that would affect Year 2 liabilities. It intends to issue a single Notice of Liability by the end of November (Packaging News). | Reliable weights and material splits, held in one place. |
The two taxes ask different questions. Plastic Packaging Tax asks how much of the plastic is recycled. EPR modulation asks whether the pack can actually be recycled. A tray can pass one test and fail the other, so the team needs to hold both in mind.
The skills FMCG packaging teams are being asked for
We have not seen hard national data on packaging technologist vacancies, so treat the following as our reading of the work rather than a statistic. The brief has widened in five ways.
- RAM fluency: knowing the material-specific criteria and which constructions trigger a red rating.
- Data discipline: accurate component weights and material splits, because PackUK has made data stability a financial priority.
- Commercial awareness: translating a design change into cost per tonne, and weighing it against shelf impact and retailer requirements.
- Food contact and safety knowledge: recycled content and mono-material swaps still have to meet food safety and shelf-life requirements.
- Line knowledge: lighter or mono-material films can behave differently on filling and wrapping lines, so efficiency and OEE need testing before launch.
- Supplier management: evidence for recycled content and recyclability usually sits with converters and film suppliers.
Pay is moving with this. We cover it separately in Packaging Technologist Salary UK: What EPR Has Done to Pay and, for the engineering side, Packaging Engineer Salary in CPG. Packaging work also touches NPD and innovation teams, because every new pack now carries a fee consequence from day one.
How to resource the extra work
Most teams absorbed the first year of EPR as a reporting task. The second year, with modulation, is a design task. The steps below suit a business that wants to resource it deliberately.
A practical sequence for hiring managers:
- Map your exposure. List packaging by SKU, material and tonnage, and mark which formats are likely to rate red. Flexible plastics are the usual starting point.
- Name an owner for RAM evidence. Decide who signs off assessments and holds the files. If the answer is nobody, that is your first gap.
- Separate project work from business as usual. Redesign programmes need protected time. If the same technologist runs trials, specs and assessments, something slips.
- Match the hire to the gap. A permanent technologist suits ongoing design and supplier work. An interim or contractor can clear a one-off backlog of assessments. See interim and contract hiring in FMCG.
- Write the role honestly. Include RAM, data and cost modelling in the job description, or you will attract candidates who expect a specification-only role.
- Plan for 2027 and drinks. If you sell drinks, build the deposit return scheme registration and labelling work into the 2027 resource plan now.
Hiring mistakes we would avoid
The first mistake is hiring a sustainability generalist to run assessments. They can manage policy and reporting, but RAM outcomes depend on how a pack is built and made. Pair them with a technologist rather than replacing one.
The second is treating EPR as a one-year compliance project. The red multiplier is scheduled to rise for two more years, so the redesign work does not end after this reporting cycle.
The third is a slow process. Strong packaging technologists with both food contact and recyclability experience are a small group, and the same pressures that apply to engineering hires apply here. A hiring process that takes two months will lose the best candidates. Where recipe and pack changes move together, involve your R&D and product development lead in the interview, and see how reformulation pressure is already reshaping those teams.
Frequently asked questions
Extended Producer Responsibility for packaging makes businesses that supply or import packaging pay for managing it once it becomes household waste. Fees are based on the weight and type of packaging. Since April 2025 the money has funded local authority collection, sorting and recycling. From 2026-27 fees are also adjusted by a red, amber or green recyclability rating.
RAM is the government's method for rating whether household packaging can be recycled in practice. Large producers must use it, assign a red, amber or green rating to each item or component, and report the results with their other packaging data. RAM 2027, published in July 2026, applies to packaging supplied in 2027.
For 2026/27, red-rated packaging pays a 20% premium over the amber fee, according to Food Manufacture. The red multiplier is scheduled to rise to 1.6 times in 2027/28 and 2.0 times in 2028/29. Green-rated packaging attracts a discount, which PackUK sets, so the saving depends on the mix of packaging reported across all producers.
Yes. Recyclability ratings depend on how a pack is built, so the people who specify materials, layers, inks and closures are best placed to assess and improve them. A technologist who can also explain the cost impact of a design change in pounds per tonne is more useful to a commercial team than one who cannot.
No. Plastic Packaging Tax is an HMRC tax, charged at £228.82 per tonne from 1 April 2026 on plastic packaging components with less than 30% recycled content. EPR is a separate scheme run by PackUK and the regulators, with fees based on weight, material and recyclability. A pack can be affected by both.
The House of Commons Library says all parts of the UK are expected to start a deposit return scheme for drinks containers on 1 October 2027, with a 20p deposit on in-scope containers. Drinks brands should expect container registration, labelling and specification work in the months before launch.