Received a PackUK Invoice? Here's What to Do

If a PackUK invoice has just landed in your inbox or on your desk, you are not alone. Thousands of UK businesses received their first EPR fee invoices in late 2025, and many found the experience confusing, unexpected, or in some cases, flat-out wrong. Double charges, inflated tonnage figures, incorrect RAM ratings applied to packaging components — the first invoicing cycle was not without its problems.

This guide walks you through everything you need to know about your PackUK invoice: what it is, why you received it, how to read it, what to do if the figures look wrong, and how to appeal. We also cover the steps you can take right now to ensure your next invoice is accurate and, ideally, lower than this one.

What Is PackUK?

PackUK is the Scheme Administrator appointed by DEFRA to manage the operational side of the reformed Extended Producer Responsibility (EPR) scheme for packaging in the UK. Established in 2025, PackUK sits at the centre of the EPR fee collection system. It is the organisation responsible for calculating how much each obligated producer owes, issuing Notices of Liability, collecting payments, and distributing funds to local authorities to cover the costs of packaging waste collection and management.

Think of PackUK as the billing engine of the EPR scheme. DEFRA sets the policy and the rules. Producers submit their packaging data to the Report Packaging Data (RPD) service. PackUK then takes that data, applies the published fee rates, and generates invoices. It also handles disputes, processes refunds, and manages the administrative apparatus that keeps the whole system running.

PackUK is not a compliance scheme in the traditional sense. Under the old Packaging Recovery Note (PRN) system, producers joined a compliance scheme that handled their obligations on their behalf. Under the reformed EPR, PackUK deals with every obligated producer directly. There is no intermediary. If you are an obligated producer, your invoice comes from PackUK and your payment goes to PackUK.

Why You Received an Invoice

You received a PackUK invoice because your business is classified as an obligated producer under the reformed EPR regulations. This means you meet the obligation thresholds set by DEFRA:

• Large producers: Over £2 million annual turnover and over 50 tonnes of packaging handled per year
• Small producers: Over £1 million annual turnover and over 25 tonnes of packaging handled per year

The process works as follows. You (or someone in your organisation) submitted packaging data to the RPD service, reporting the types, materials, weights, and volumes of packaging your business placed on the UK market. PackUK received this data from DEFRA, applied the relevant per-tonne fee rates for each material, factored in any modulation adjustments based on RAM ratings, allocated costs by nation of sale, and produced your invoice.

Before the invoice itself, you should have received a Notice of Liability. This is a formal document confirming that PackUK has identified your business as an obligated producer and setting out the basis on which your fees will be calculated. The Notice of Liability is an important document. If you did not receive one, or if the details on it are incorrect, that is the first thing to address.

Your PackUK invoice is only as accurate as the data you submitted. If your RPD data contained errors in tonnage, material classification, or RAM ratings, those errors will be reflected directly in your invoice.

Understanding Your PackUK Invoice: Line by Line

A PackUK invoice is not a single lump-sum bill. It is a detailed breakdown of fees calculated for each packaging component your business reported. Understanding the line items is essential, both for verifying accuracy and for identifying where your costs are highest.

Base Fee by Material

The largest component of your invoice is the base fee per tonne for each material type. Every material in the EPR system has a different per-tonne rate, reflecting the differing costs of collecting, sorting, and reprocessing that material. Plastic carries the highest per-tonne cost, typically £235–260 per tonne (and is also subject to the Plastic Packaging Tax if it contains less than 30% recycled content), while glass and wood sit at the lower end. Your invoice will show each material separately, with the applicable rate and the tonnage from your RPD submission.

Modulation Adjustment

From the 2026-2027 compliance year onwards, each packaging component is subject to a modulation adjustment based on its RAM (Recyclability Assessment Methodology) rating. Green-rated packaging (fully recyclable) receives a fee discount. Red-rated packaging (not recyclable) incurs a premium. Amber-rated packaging sits near the unmodulated baseline. If your invoice covers the 2025-2026 year, modulation was not yet applied, but from 2026-2027 with a 1.2x modulation factor, this line item becomes increasingly significant. Check our detailed breakdown of EPR fees for 2026-2027 for specific rate ranges.

Nation of Sale Allocation

The EPR scheme allocates packaging waste management costs by nation: England, Scotland, Wales, and Northern Ireland. Your invoice reflects where your packaging was sold, not where your business is headquartered. If you sell across multiple UK nations, your invoice will show separate cost allocations for each. The per-tonne rates can vary slightly by nation due to differing local authority collection costs.

Administrative Charges

PackUK applies a modest administrative charge to cover the costs of running the scheme — invoicing, dispute resolution, payment processing, and reporting. This is typically a small percentage of the total fee and is shown as a separate line item.

Common Issues with PackUK Invoices

The first cycle of PackUK invoicing in late 2025 was not without problems. While the system is improving, a number of issues affected producers across the UK. Here are the most common problems to watch for.

Double Charging

The double-charging issue affected an estimated several hundred producers and was attributed to a data processing error during the first bulk invoicing run. PackUK identified the issue in early 2026 and began proactively contacting affected businesses. However, if you have not been contacted and believe you were double-charged, do not wait — raise the issue yourself.

Incorrect Tonnage Figures

Some producers found that the tonnage figures on their PackUK invoice did not match the data they submitted to the RPD service. This can happen for several reasons:

• Data entry errors in the original RPD submission (the most common cause)
• Unit conversion mistakes (reporting in kilograms when the system expected tonnes, or vice versa)
• Incomplete submissions where not all packaging components were included, leading to estimated figures being applied
• Data transfer errors between the RPD system and PackUK's invoicing platform

If the tonnage on your invoice looks wrong, the first step is to compare it against your original RPD submission. If the RPD data itself was incorrect, you may need to submit a correction through the RPD service before disputing the invoice with PackUK.

Wrong RAM Rating Applied

This is a particularly costly error. If your RPD submission did not include complete recyclability information for a packaging component, PackUK may apply a worst-case RAM rating (Red) by default. A Red rating means you pay the highest modulated fee for that material, potentially 10–12% above the base rate in 2026-2027, and significantly more in future years as the modulation factor increases.

The fix is to ensure your RAM data is complete and accurate before submission. If a worst-case rating was applied incorrectly, you can dispute it by providing evidence of the actual recyclability of your packaging — but it is far better to get this right at the submission stage.

Invoiced Below the Threshold

Some businesses received invoices from PackUK despite believing they fall below the obligation thresholds. This can happen if:

• Your turnover or tonnage was estimated by the regulator based on incomplete data
• Your business was registered as an obligated producer in a previous year and the registration was not updated
• A subsidiary or group company submitted data that was incorrectly attributed to your entity

If you believe you are genuinely below the threshold, gather evidence of your turnover and packaging tonnage and submit it through the PackUK dispute process. You should also check your registration status on the RPD portal.

How to Appeal a PackUK Invoice

If you have identified an error on your invoice, the appeal process is straightforward but requires attention to detail and documentation. Here is the step-by-step process.

Step 1: Review Your Notice of Liability

Before disputing the invoice itself, check your Notice of Liability. This document sets out the basis for your fee calculation, including your obligation status, the compliance period, and the data used. If any of these details are incorrect, the Notice of Liability is where the problem starts.

Step 2: Compare Invoice Figures Against Your RPD Submission

Pull up the packaging data you submitted to the RPD service and compare it line by line against the invoice. Check tonnage figures for each material, the RAM ratings applied to each component, the nation of sale allocation, and any modulation adjustments. Document every discrepancy you find.

Step 3: Gather Your Evidence

For each discrepancy, prepare supporting evidence. This might include:

• Screenshots or exports of your original RPD submission
• Corrected data with supporting documentation (weight certificates, supplier specifications)
• RAM assessment records showing the correct rating for each component
• Business records confirming turnover and tonnage figures

Step 4: Submit Your Dispute Through the PackUK Portal

PackUK operates an online dispute portal where you can submit formal appeals against invoice charges. Log in with the same credentials used for your PackUK account, select the invoice in question, specify which line items you are disputing, upload your evidence, and submit the dispute. You will receive a reference number for tracking.

Step 5: Wait for the Initial Response

PackUK aims to respond to disputes within 30 business days. During this period, you are not required to pay the disputed amount (though undisputed portions should still be paid on time to avoid late penalties). PackUK may contact you for additional information or clarification.

Step 6: Escalate If Necessary

If your initial appeal is unsuccessful and you believe the decision is incorrect, you can escalate to an independent review panel. The escalation must be submitted within 15 business days of receiving the initial appeal decision. The independent panel will review the evidence from both sides and issue a binding decision.

How to Prevent Incorrect Invoices

The best way to deal with a wrong invoice is to never receive one in the first place. The accuracy of your PackUK invoice is a direct function of the accuracy of the data you submit to the RPD service. Get the data right, and the invoice takes care of itself.

Accurate Tonnage Data

Use calibrated scales and proper weighing procedures for every packaging component. Do not estimate weights unless absolutely necessary, and document your methodology when you do. Cross-reference your packaging tonnage against purchase orders, supplier invoices, and production records to catch discrepancies before they reach the RPD submission.

Correct Material Classification

Every packaging component must be classified against the correct material type in the DEFRA framework. Misclassifying a material — for example, reporting a fibre composite as paper/card — will produce an incorrect fee calculation. If you are unsure about a material classification, check the DEFRA material definitions or consult with your packaging supplier.

Proper RAM Ratings

Incomplete or inaccurate RAM assessments are one of the most expensive data errors a producer can make. If you do not submit a RAM rating, the worst-case assumption (Red) will be applied. If you submit an overly optimistic rating that is later corrected, you may face a fee adjustment plus potential compliance consequences. Conduct thorough RAM assessments using the five-stage methodology for every household packaging component. For detailed guidance, see our RAM assessment guide.

Data Management Tools

Manual data collection using spreadsheets is the root cause of most submission errors. Mistyped figures, formula errors, missing components, and version control problems all lead to inaccurate RPD submissions, which lead to inaccurate invoices. Purpose-built compliance tools eliminate these failure modes by validating data at the point of entry, running automated checks, and producing submission-ready outputs that match the RPD format exactly.

Every error in your packaging data costs you money. An overstated tonnage figure means you pay fees on packaging you did not place on the market. A missing RAM rating means you pay the Red premium on packaging that might be Green. Data accuracy is not a compliance nicety — it is a direct line item on your P&L.

PackUK Payment Terms and Late Penalties

Understanding when and how to pay is just as important as understanding what you owe. PackUK operates strict payment terms, and missing a deadline has consequences.

Payment Window

Once your invoice is issued, you typically have 30 days to make payment in full. The exact due date is printed on the invoice. Payment can be made via bank transfer to PackUK's designated account, with your invoice reference number included in the payment reference. PackUK does not currently accept payment by credit card or direct debit for standard invoices, though instalment arrangements may be available for larger sums.

What Happens If You Do Not Pay

If payment is not received by the due date, PackUK will issue a reminder notice giving you an additional 14 days to pay. If payment is still not received after the reminder period, the following consequences apply:

• Late payment interest: Interest accrues on the outstanding amount at 8% above the Bank of England base rate, calculated from the original due date
• Administrative surcharge: A fixed surcharge is added to cover the cost of chasing late payments
• Enforcement referral: Persistent non-payment may be referred to DEFRA for regulatory enforcement action, which could include compliance notices, financial penalties, or public disclosure of non-compliance

Disputed Amounts

If you have submitted a formal dispute through the PackUK portal, the disputed portion of the invoice is held in abeyance while the dispute is resolved. You are not required to pay the disputed amount during this period. However, you must still pay any undisputed portions of the invoice on time. Failing to pay the undisputed balance while a dispute is open will still trigger late payment interest and administrative charges on that portion. See our guide to EPR penalties and fines for more detail on the consequences of non-payment.

Frequently Asked Questions

What is PackUK and why did I receive an invoice?

PackUK is the Scheme Administrator appointed by DEFRA to manage the collection of EPR fees from obligated packaging producers in the UK. If you placed packaging on the UK market and meet the obligation thresholds (over £2 million turnover and over 50 tonnes for large producers, or over £1 million turnover and over 25 tonnes for small producers), PackUK will issue you a Notice of Liability followed by a fee invoice based on the packaging data you submitted to the RPD service.

How do I appeal a PackUK EPR invoice?

Review your Notice of Liability and compare the invoice figures against your original RPD submission data. If you find discrepancies, submit a dispute through PackUK's online dispute portal with supporting evidence including your original submissions, corrected data, and any correspondence. PackUK aims to resolve disputes within 30 business days. If the initial appeal is unsuccessful, you can escalate to an independent review panel within 15 business days of the decision.

What if I was double-charged by PackUK?

Double-charging was a known issue during the late 2025 invoicing cycle, which PackUK publicly acknowledged. If you believe you have been charged twice for the same packaging data, contact PackUK immediately through their dispute portal and provide both invoice references. PackUK has committed to processing refunds for confirmed duplicate charges within 15 business days of verification. Do not pay a duplicate invoice — dispute it first.

How are EPR packaging fees calculated on my PackUK invoice?

Your invoice is calculated based on four components: the base fee per tonne for each material type, a modulation adjustment based on the RAM rating of each packaging component (from 2026-2027 onwards), the nation of sale allocation across England, Scotland, Wales, and Northern Ireland, and administrative charges. The modulation factor for 2026-2027 is 1.2x, meaning Green-rated recyclable packaging receives a fee discount while Red-rated non-recyclable packaging incurs a premium above the base rate.

The Bottom Line: Accuracy Saves Money

Your PackUK invoice is a direct reflection of the packaging data you submitted to DEFRA. If the data was accurate, the invoice should be accurate. If the data contained errors, the invoice will too — and in most cases, errors cost you more rather than less.

The producers who consistently pay the correct amount (and not a penny more) are the ones who invest in getting their data right at the point of submission. They weigh accurately, classify correctly, conduct thorough RAM assessments, and use systems that catch errors before they reach the RPD portal. They do not need to appeal invoices because the invoices were right in the first place.

If your current invoice is wrong, dispute it. Use the step-by-step process outlined above, gather your evidence, and submit your appeal within the 60-day window. But while you are doing that, also ask yourself: what needs to change in my data management process to prevent this from happening again?

The modulation factor increases every year, and the Deposit Return Scheme launching in 2027 will add further complexity for drinks producers. The financial impact of data errors will only grow. A wrong RAM rating that costs you an extra £500 this year will cost you an extra £2,000 by 2028-2029. An overstated tonnage figure that adds £1,000 to this year's invoice will compound year on year if not corrected. The time to fix your data processes is now.

The cheapest way to reduce your EPR bill is to make sure you are only paying for what you actually owe. Accurate data is not an overhead — it is a cost reduction strategy.