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Guidance

Methodology and procedure for calculating 2026 to 2027 (year 2) payments

Updated 21 April 2026

This guidance should be read with the notice of assessment letter which was sent to each local authority between November 2025 and January 2026.

The notice of assessment letter sent to local authorities in January outlines:

  • the total extended producer responsibility (EPR) for packaging payments PackUK anticipates making for the financial year 2026 to 2027
  • when payments will be made

This guidance provides more detail on how this anticipated payment has been calculated.

Notice of assessment letters provided in January 2026 relate to anticipated payments to be made in the financial year 2026 to 2027 only.

The payment amount shown in your notice of assessment letter reflects what PackUK (the scheme administrator) anticipates paying to your local authority at this time, however your actual payment may still differ from this figure in some limited circumstances, including:

  • in the event of a successful complaint or appeal from producers or local authorities
  • if PackUK does not receive sufficient funds from producers

Final payment amounts will be confirmed in your quarterly grant determination letters, which your authority will receive before each scheduled payment (please refer to your notice of assessment letter for the payment schedule).  

PackUK may collect updated data and improve modelling methods used to assess payments in future years. This may contribute, along with other factors, to changes in the distribution and values of future payments tolocal authorities.

Two amendments have been made to the 2025 to 2026 (year 1) methodology to calculate 2026 to 2027 (year 2) payments.This includes a direct change for Wales only.

Firstly, a 1.93% uplift has been applied to account for the impact of inflation. This inflation adjustment is equal to the increase in the Consumer Price Index between 2025 to 2026 and 2026 to 2027 in the . Read Section 5 for further details.

Secondly, for Wales only, an adjustment in the calculation of payments to Welsh local authorities has been made. This will account for the regulatory requirement placed on Welsh local authorities to meet a minimum statutory municipal recycling rate. This approach aims to account more directly for the distinct regulatory context in which Welsh local authorities operate.

PackUK has undertaken a supplementary calculation for local authorities in Wales. This assesses the impact that complying with this regulatory requirement has on service costs.

This supplementary calculation informs an adjustment that PackUK applies to the assessment of payments to local authorities in Wales. The adjustment is made to account for the relative efficiency of services in Wales and is proportionate to the progress that local authorities in Wales have made against statutory minimum recycling rates.

Find more information about the supplementary calculation to account for statutory recycling target (Wales only) in a later section.

All other elements of the calculations remain the same as year one.

We anticipate updating this guidance on a yearly basis.

1.Scope of payments

This section provides a description of the costs that PackUK has accounted for in determining a local authority’s payment.  

Ի(ٳEPRfor packaging regulations), PackUK (the scheme administrator) must assesslocal authorityEPRfor packaging payments for 2026 to 2027, including:

  1. Efficient disposal costs in total and for each packaging category - including all expenses relating to the proper disposal, recycling, or treatment of waste, ensuring it is done in an environmentally friendly and cost-effective manner. It also includes the costs of providing public information about the management of household packaging waste, including the costs associated with both the planning and the execution of any information campaigns.
  2. Waste income from the expected sale of household packaging waste for each packaging category.
  3. Net efficient disposal costs for each packaging category - this is calculated by considering the efficient disposal costs minus the expected income from the sale of household packaging waste.
  4. Chargeable disposal costs - for the 2026 to 2027 assessment year, this will be the total net efficient disposal costs for all packaging categories.

Under regulation 70(6) of theEPRfor packaging regulations, “efficient disposal costs” are disposal costs that an authority would incur providing an efficient waste management service. A relevant authority provides an efficient waste management service if the disposal costs of the authority are as low as reasonably possible, taking into account: 

  • the waste management service provided by thelocal authority  
  • any other factors specific to thatlocal authority, or to the area in relation to which it exercises its waste management functions, which in the opinion of PackUK are likely to affect its disposal costs

Efficient disposal costs include costs incurred for the:

  • collection from kerbside, communal collections, bring sites and household waste recycling centres (HWRCs), where relevant
  • handling, sorting, treatment, and disposal of household packaging waste net of relevant income, including administration and communication costs such as the costs to the authority of providing public information about the management of household packaging waste
  • planning and carrying out information campaigns

“Net efficient disposal costs” means the efficient disposal costs in an assessment year, less the expected income for that year from sale of household packaging waste. 

2.Local authority packaging cost and performance model (LAPCAP)

Costslocal authoritiesincur in the management of household packaging waste have been assessed using a model developed by Defra on behalf of the 4 UK nations. This model is calledLAPCAP.LAPCAPcalculates the net efficient waste management costs of managing household packaging waste for each individuallocal authority. 

The legislative requirements underpinning the development of the model are set out in theEPRfor packaging regulations. In determining net efficient disposal costs for the 2026 to 2027 assessment year,LAPCAPmay consider:

  • frequency, pattern and type of collections of household packaging waste in the area of thatlocal authority(“the relevant area”)
  • population density in the relevant area
  • type and accessibility of dwellings in the relevant area
  • levels of deprivation in the relevant area
  • government policies and the regulatory requirements affecting waste management to which the authority is subject
  • any other factor PackUK considers relevant to the assessment

The full legislative requirements for the assessment oflocal authoritycosts, and thereforeLAPCAP, are detailed in theEPRfor packaging regulations.

ܰԳٱLAPCAPdoes not include costs associated with business waste, street bin waste or litter, in accordance with those regulations.

Find worked examples for the LAPCAP model on ǸԹ.

Payments will cover the cost of the packaging element of the waste stream for eight high-level packaging material types.

The packaging categories set out in theEPRfor packaging regulations are:

  • ܳԾܳ
  • ٱ
  • paper and card
  • پ
  • ɴǴǻ
  • fibre-based composite
  • other materials

Drinks containers made from polyethylene terephthalate (PET), steel, or aluminium between 150ml to 3l in size are excluded fromEPRfor packaging disposal fees until 2028. They will be in scope from 2028 only if a Deposit Return Scheme (DRS) is not in place by that time. Packaging collected in the food and garden waste streams are also excluded.   

The following waste streams are included inLAPCAP:

  • dry recyclate collected commingled or separately from kerbside, bring sites orHWRCsincluding the packaging materials listed in theEPRfor packaging regulations
  • residual waste including the packaging materials listed in theEPRfor packaging regulations

Iflocal authoritiesprovide dry recyclate offtake and residual waste treatment and disposal, the net efficient disposal costs calculation will include provision for a transfer station.

Tipping away payments

Tipping away payments apply when the county council, acting as the waste disposal authority (WDA), is unable to provide the district and borough councils, waste collection authorities (WCA), with a suitable location to tip waste within a reasonable distance of the boundary of their area.

ճLAPCAPmodel excludes provision for costs related to tipping away payments. In cases where a tipping away payment is necessary, theLAPCAPmodel assumes that theWDAwill continue to make this payment. ճLAPCAPmodel determines aWCA’s efficient costs. If theWCAhas to transport waste further than reasonable, this would be deemed inefficient, and a tipping away payment from theWDAto theWCAis still justified.

3.LAPCAPٳǻDZDz

This section describes how the model calculates the net efficient disposal costsEPRfor packaging payment for eachlocal authority.  

LAPCAPuses a combination oflocal authority specific data and comparative data to calculateEPRfor packaging payments for eachlocal authorityin the UK. For example:

  • tonnes - reported in Waste Data Flow
  • comparative data - groupings based on reported cost data from a sample oflocal authorities

LAPCAP’s methodology can be summarised in a simplified way[footnote 1] as follows:

Recylate collection cost + recyclate handling, sorting and transport costs - income from sales of recyclate

+

Residual collection cost + residual handling, sorting and transport costs + residual treatment and disposal + disposal overheads

= Net payment tolocal authority

For WCAs and WDAs respectively disposal and collection costs are omitted where appropriate and an adjustment is made to account for recycling credits unless there is information that other local arrangements are in place.

More detail on how the model handles two tier authorities and recycling credits is provided in the separate sections below.  

The model is made up of 4 modules, which come together to produce output data. This output data is used in the calculation above to produce final outputs. The 4 modules are:  

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  • waste flow
  • gate fees
  • cost per tonne

The metadata module

This provides thelocal authoritycharacteristics, such as:

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  • dzܲԳٰ
  • type oflocal authority
  • rurality level
  • deprivation level
  • household numbers by property type
  • collection system for everylocal authorityin the UK

This data is used as inputs to the other modules.

The waste flow module

The waste flow module convertslocal authorityreported data on movements of waste into the relevant packaging tonnages for the model. It draws on the web-based system used by UKlocal authoritiesfor municipal waste data reporting to government. The module uses tonnage data fromcombined with packaging waste composition data from the,Իto estimate:

  • tonnages of packaging waste collected by each collection method, for example, from kerbside, bring sites andHWRCs
  • tonnages going to each disposal method

Scheme type refers to the collection of the material tonnage in the following service:

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  • ܱپ-ٰ𲹳 į
  • two stream 

Scheme type data is based onWRAPlocal authorityportal data held for 2021 to 2022. This year has been used to align with the most recent audited tonnage data set available at the outset of theLAPCAPmodel build.

Understanding the collection schemes used bylocal authoritiesis needed to accurately distribute tonnage based on scheme data.

In November 2024,local authoritieswere given the opportunity to confirm their scheme type for the 2021 to 2022 period. Where applicable, the feedback has been incorporated to ensure consistency. Further updates will be applied for Year 2 of theEPRfor packaging scheme.

This module provides all inputs on tonnages and movements of waste for the model. Where composition data is not sufficiently detailed, additional sources have been used including:

  1. Data submitted by producers in the Report Packaging Data (RPD) system for 2024 – there are categories in the waste composition studies that contain indeterminate small amounts of in-scope wood, ‘other’ and fibre-based composite packaging.RPDdata is used to determine the appropriate proportions here based on which values lead to alignment of in-model tonnages with these producer-reported tonnages.
  2. ճreport for plastic is used to determine the proportion ofPETbottles in England, Scotland, Wales and Northern Ireland that are excluded fromEPR. This is applied to theWRAP2017 data to split this category into in-scope and out-of-scope material. Before the implementation ofDRS, the relevant exclusion fromEPRfor packaging payments in year one and year 2 Lapplies specifically to drinks containers made from polyethylene terephthalate (PET), steel, or aluminium, ranging in size from 150ml to 3 litres. This exclusion remains in place until 2028. The waste composition study categories for steel and aluminium that is excluded on this basis are sufficiently detailed that we do not require additional data.

The gate fees module

The Gate Fees Survey provided by WRAP gives reported gross and net gate fees for a selection of local authorities. As part of the modelling, there is a requirement to net off the income from the sale of recyclate, and to apportion costs between EPR-eligible materials. However, he Gate Fees Survey does not provide this level of granularity. The gate fees module is required to calculate the cost per tonne of disposing of each waste material at different facilities, by taking into account material values.

It does this by apportioning reported rebates per facility (i.e. gross minus net gate fees from the Gate Fees Survey) between materials and using this to calculate an in-model net gate fee per material going to each facility type. These calculated net gate fees include bulking, haulage and transfer costs. More detail on the process of calculating net gate fees is provided below. Average gate fees are used because it is not considered possible at this time to reliably model the factors influencing gate fees in different  local authorities.  

In future we will explore introducing more sophisticated methodologies to more accurately model the different gate feeslocal authoritiespay. We also plan to adjust calculated gate fees to account for transfer and haulage costs differing betweenlocal authorities.

Step 1: Calculating median gross gate fees for different disposal methods

For dry recyclate sent toMRFs, the gate fees module calculates a median gross gate fee for each nation. This uses data from the 2022 to 2023for the costs of handling materials sent toMRFs.

For reprocessors, re-use, exporter re-use and exporter recycling the gate fees module calculates a single median gross gate fee for each material type. It uses data provided by Welsh Local Government Association (WLGA) and WIDP which is then applied to alllocal authoritiesacross the UK. All these disposal methods are assigned the same median gross gate fee for each material type due to data limitations.

Step 2: Accounting for income: calculating rebate values for each material going to each facility type

This section explains how we calculate a rebate value for each material at each facility type. A single rebate value is calculated for each facility type and material type and is then applied to alllocal authoritiesacross the UK. The rebate value is used to calculate net gate fees in the next step.

Income from the sale of dry recycling fromMRFs, reprocessors, re-use, exporter re-use and exporter recycling is calculated by taking the difference between the median gross and median net gate fees and apportioning this rebate value across different materials. The median net gate fee in this case is the median of the reported gate fee from the same data sources mentioned above which were used to calculate the median gross date fee (WRAPgate fee survey, WLGA and WIDP). This is different from the calculated net gate fees which the module gives out as its main output.  

For each facility type we use the difference between gross and net gate fees to determine a total rebate for all materials (for example, the rebate for a tonne of mixed recycling going to a MRF). We then calculate how much of this total rebate should be assigned to each material based on material prices fromand tonnages of each material type going to each facility from the Waste Flow Module. Data from Lets Recycle are available on a month-by-month basis for several years. Prices from the financial year 2022 to 2023 are used to correspond to the gate fee data.

In summary, eachEPRfor packaging material category is assigned a per-tonne rebate value for each facility type that is then used to calculate costs for each relevantlocal authorityacross the UK. For more information on this calculation please see the worked examples.

Calculating net gate fees using the rebate values

Net gate fees for each material for each facility type, and in each nation forMRFs(for example, plastic going toMRFsin Scotland or glass going to reprocessor anywhere in the UK) are calculated by taking the median gross gate fee for that facility type and subtracting the relevant rebate value (in this case rebate of plastic going to MRF in Scotland, rebate of glass going to reprocessor).

Disposal costs for eachlocal authorityis then determined by multiplying the calculated net gate fees by material tonnages going to each facility from the Waste Flow Module.

For residual waste sent to all facility types, (such as energy from waste, mechanical biological treatment, landfill) the gate fee module calculates a median net gate fee for each facility type directly from theWRAPGate Fee Survey. This median net gate is then multiplied by the material tonnages going to each facility from the Waste Flow module to determine disposal cost. This means that in practice (and in terms of impact on base fees) costs and any income from these facilities is just apportioned evenly across materials according to tonnage. Please refer to the worked examples annex for a detailed breakdown of how this is calculated.

Differences in cost per tonne figures between differentlocal authoritiescan be driven by differences in assumed waste composition going to each disposal method and the varying income from material sales based on these differences.

Although national compositions are used, we do make individual adjustments, for example where we know materials are collected separately. This can have an impact on cost per tonne figures for some disposal methods, includingMRFs. For more information, please refer to the worked examples document.

An addition is made to all MRF gate fees (for sorting commingled streams and separately collected materials) to cover the additional cost of compliance with the following:

The additional payment relates to the day-to-day operational costs as estimated in theEPRfor packaging impact assessment and increases to regulator fees.

Overhead costs

Alllocal authoritiesare paid the same per household overhead costs. These costs reflect the administration, contract management and otherlocal authoritycosts of managing waste disposal functions andHWRCs. Local communication campaign costs are also included.

Overheads are calculated on a per household basis and on the average cost per tonne per household. Data on household numbers comes from 2021 data from the() and(). We calculate a single per household cost using the data from the Request for Information (RFI) then multiply by theONSand SNR household number estimates to get total overheads for eachlocal authority.  ճRFIis a survey sent tolocal authoritiesto request information on the collection of up-to-date actual cost data of waste collection and disposal services, where relevant for the use ofLAPCAP.

Overheads per tonne can differ betweenlocal authoritiesdue to the differences in the number of tonnes collected per household. If the average household in onelocal authoritygenerates more waste than the average household in anotherlocal authority, the overhead per tonne will differ.

Overhead costs are not included in gate fees forHWRCsand treatment and disposal such as landfill, incineration, and energy from waste (EfW)[footnote 2]so are added to reflect the fulllocal authoritycost of managing waste disposal functions.

Private finance initiative (PFI) contracts

PFI contracts involvelocal authoritiestransferring the responsibility of financing and managing waste infrastructure, such as waste transfer stations, recycling centres, and EFW plants to private companies.Local authoritiespay the private companies based on the performance and of the services provided over the contract period.

Wherelocal authoritieswith PFI contracts responded toWRAP’s Gate Fee survey, their data has been incorporated in the model. Therefore, these costs are reflected in the overall average figures used in the analysis. Data held by Defra and the Waste Infrastructure Delivery Programme (WIDP) relating to Mechanical Biological Treatment (MBT) gate fees has been included in gate fee costs.

Flexible Plastic Fund (FPF) FlexCollect Scheme

FlexCollect is a pilot project to test and refine methods for collecting and recycling flexible plastic packaging at the household level.

For thoselocal authoritiesknown to be running a formal plastic film pilot as part of the FlexCollect UK scheme an additional payment has been made to cover the reported cost of operating the pilot in 2025 to 2026. ճLAPCAPmodel outputs calculatelocal authorities’ FlexCollect payment, this is included in the notice of assessment letter.

The cost per tonne module

The cost per tonne module calculates the efficient costs of collecting packaging waste for alllocal authoritiesfrom:

  • recyclate and residual kerbside collections
  • bring sites
  • HWRCs

This module groupslocal authoritiesto calculate cost per tonne figures for waste that is collected from each of these sources, reflecting the fact that collection costs vary depending on alocal authority’scharacteristics. The costs include:

  • front-line staff
  • vehicles (running costs, maintenance, fuel and annualised capital expenditure)
  • containers provided to householders (annual replacement and annualised capital expenditure)
  • overheads including management, admin, equipment, IT, local communication campaigns. 
  • capital expenditure, which is reflected in the cost-per-tonne values. It is annualised - for example, if a local authoritybuys a vehicle with a five-year life expectancy, we attribute one fifth of the costs per year.

Cost per tonne figures for kerbside recyclate and residual collection are determined by using a grouping method. The grouping method creates 10 groups oflocal authoritiesfor residual collections and 10 groups for recycling collections. To create these groups, reported cost data[footnote 3]from a sample of 49local authorities from across the UK plus actual cost data from Welshlocal authorities, provided by the WLGA, analysed to identify the common characteristics which most strongly influence these collection costs. These characteristics are listed in thelocal authority groupings (residual and recycling) section of the guidance and examples of how this works can be viewed in the worked examples annex.

To grouplocal authoritiesexpected to incur comparable costs per tonne of waste collected, the model uses:

  • findings from this analysis
  • legal requirements on the factors we must consider
  • data onlocal authoritycharacteristics from the metadata module

Calculating a cost per tonne

LAPCAPgroupsthe local authoritiesaccording to their characteristics to create:

  • 10 groups oflocal authoritiesfor recycling collections
  • 10 groups oflocal authoritiesfor residual collections

More information on these is in the sectionlocal authoritygroupings (residual and recycling). The average cost per tonne for sampledlocal authoritiesin each group is used to determine cost per tonne figures for every group.

HWRC costs have been based on data provided by our sample WDAs plus the unitary authorities in theRFIsample. Our ambition is to obtain a wider sample in the future.

Due to limitedRFIcost data available for HWRC and bring sitesLAPCAPuses a method where the overall average cost per tonne across alllocal authoritiesis applied.

4.Local authoritygroupings (residual and recycling)

The factors used to grouplocal authorities[footnote 4]for kerbside recyclate collections are:

  • collection frequency – for example every week, fortnightly, 3-weekly
  • rurality (% urban) - rurality % based on highly rural, rural and urban
  • proportion of flats percentage of housing units in each area that are flats compared to other residential properties based on the 2021ONScensus and National Records for Scotland estimates
  • deprivation - proportion of indices of deprivation (IMD) band D and E, lower layer super output areas (LSOA) in the authority
  • UK dzܲԳٰ
  • tonnes collected per household - calculated byLAPCAPto help determinelocal authoritywaste collection groupings as the tonnes collected from the kerbside as dry recycling or residual waste
  • collection scheme proportion – the proportion of households served by each specific waste collection scheme for commingled, multi-stream and two-stream
  • food collection flag – a binary indicator, set to 1 if alocal authorityhas reported collecting waste through a dedicated food waste collection stream, and 0 otherwise

For kerbside residual collections this module uses the following factors to grouplocal authorities. The same definitions apply to these factors as above:

  • collection frequency 
  • rurality (% urban) 
  • proportion of flats 
  • deprivation 
  • country 
  • tonnes collected per household 
  • garden collection flag – a binary indicator, set to 1 if alocal authorityhas reported collecting waste through a dedicated garden waste collection stream, and 0 otherwise
  • bring site flag – a binary indicator, set to 1 if alocal authorityhas reported collecting waste through bring sites, and 0 otherwise

Authorities are grouped by finding their closest comparators for each of these variables.Local authritiesare placed in groups with othersthat share the most similarities across the factors [footnote 5].    

All local authorities within a group are allocated the same cost per tonne calculated from an average of the RFIs in each group. Differences in cost per tonne figures within a group can be caused by differences in assumed waste composition- this is calculated on an individual local authority basis. For example, if a local authority is known to have a separate glass collection, a separate calculation is performed based on tonnage reported for that one component.

Rurality and Deprivation

Local authoritiesare assigned to a rurality deprivation group, a dry recycling group and a residual group. The cost per tonne for each stream is based on the group thelocal authorityis in. More information on this is provided in thelocal authoritygroupings section.

Household numbers

Household numbers are used in 2 ways in the model: 

  • to determine overheads
  • to grouplocal authoritiesfor collection costs

Data on numbers of households is from the:

  • for England and Wales
  • for Scotland
  • for Northern Ireland

These datasets will be kept under review to ensureLAPCAPincludes the best possible data.

To determine overheads, the cost per household comes from the RFIs supplied bylocal authoritieswith disposal functions, for example Unitary authorities and WDAs. These overheads also include the costs for managingHWRCsand bring sites. Cost per household is then multiplied by numbers of households in eachlocal authority.

When groupinglocal authoritiesfor collection costs, 3 factors use household data:

  1. Proportion of flats which uses2021 council stock data for England.
  2. Proportion of communal collections which useregarding the number of households served.
  3. Tonnes per household which usesregarding the number of households served.

Although household data comes from different sources, this data is the most consistent and best available data.

Due to the difference in cost drivers between dry recycling and residual waste, a singlelocal authoritycan be in one group for its dry recycling collections and bring sites and another group for residual andHWRCs.

Statutory joint waste disposal authorities (SJWDAs) and county councils

SJWDAs and county councils don’t appear inlocal authoritygroupings because these groupings are only used to determine collection costs. We do not currently have an equivalent grouping method for disposal costs due to the variety of different factors that drive these costs and limited data on these factors.   

Changes to groupings in future years

Collection cost groupings are something that we plan to recalculate each year ofEPRfor packaging. For example, if alocal authority’s grouping characteristics change from year 1, this could mean thelocal authoritymoves groups when groupings are recalculated.

Due to the nature of the analysis, changes in the characteristics of somelocal authoritiescould affect the grouping of others, even if those authorities’ characteristics have not changed themselves. The cost per tonne for each stream is based on the relevant group thelocal authorityis in.

A table showing the groups that eachlocal authorityis in is provided in Annex B.

5.Bringing it all together – calculating the provisional output

Several functions combine the outputs of the 4 modules to produce the provisional outputs. For instance, gate fees are combined with disposal tonnages to calculate disposal costs. These costs are then provided as outputs split by various factors, including waste stream, packaging category andlocal authority.

More information on this can be found in the worked examples annex but the following figure and explanatory text provide a summary[footnote 6] of how outputs from the 4 modules come together:

Recylate collection cost + recyclate handling, sorting and transport costs - income from sales of recyclate

+

Residual collection cost + residual handling, sorting and transport costs + residual treatment and disposal + disposal overheads

= Net payment tolocal authority

The cost per tonne module gives estimated kerbside, HWRC and bring site collection costs per tonne of residual and recycling waste for eachlocal authority. These outputs are then combined with tonnages from the waste flow module to calculate the:

  • dry recycling kerbside collection cost
  • residual kerbside collection cost
  • HWRC collection cost and bring site collection cost

This is done for each packaging category material and for the total collection costs across all household packaging waste.

For dry recycling kerbside collection costs, the impact that volume has on collection costs is taken into account.

This is done in the following way:

  1. Multiplying the cost per tonne figure (provided by the cost per tonne module) by the total tonnage eachlocal authoritymanages in dry recycling kerbside collections.
  2. This calculates the total cost of collecting dry recyclate (packaging and all other waste).
  3. This total cost is then apportioned across materials based on the proportion of each material by volume.
  4. The estimated volume of each material in the dry recycling stream is calculated through the tonnage and a corresponding bulk density value (data provided byWRAPand supported by the data collected in the Bulk Density Factors Desk Review 2022). More information on this can be found in Annex C.
  5. Volume apportionment is applied across all materials (both in scope and out of scope) as all materials are collected from the same collection vehicles.

Please refer to the worked examples for more detail.

Therefore, the calculated volume of out-of-scope materials directly affects the cost apportionment ofEPRfor packaging materials. For example, if a givenlocal authoritycollects a large amount of low-density non-packaging in their dry recycling stream, this will mean a lower proportion of collection costs are allocated to higher-density packaging materials. This adjustment recognises that volume is commonly the limiting factor in dry recycling collections.

Dry recycling composition varies betweenlocal authoritiesdue to various factors, such as:

  • type of recycling collection scheme
  • what materials are recycled
  • demographic

The data we use comes from Waste Data Flow therefore the information provided impacts varying factors. This can mean that the subsequent collection cost per tonne for kerbside dry recycling can vary even forlocal authoritieswithin the same group.

Costs are inflated to the desired year using the Office for Budget Responsibility (OBR) Retail Prices Index (RPI) inflation forecasts.

Residual handling, sorting, and transport costs and residual treatment and disposal costs are calculated using the:

  • national UK average net gate fees for the different disposal methods from the gate fees module
  • tonnages for each packaging category material from the waste flow module

The handling, sorting and transport net of income of dry recyclate is calculated using the gross gate fee[footnote 7]and material specific rebate[footnote 8]taken from the Gate Fee Module as a cost per tonne. This is multiplied by the tonnage for each packaging category taken from the Waste Flow Module. The gross cost and adjustment for income is shown in your notice of assessment letter.

Disposal overheads have been determined by multiplying the average disposal overhead costs per household (taken from the local authorities who returned RFIs, including disposal overheads costs) by the numbers of households in eachlocal authority.  

These overhead costs reflect the administration, contract management and otherlocal authoritycosts of managing waste disposal functions.

Data on the number of households is from the:

  • for England and Wales
  • estimates from 2021 for Scotland
  • for Northern Ireland

6. Use of inflation indexes

For year one of EPR for packaging, the Retail Prices Index (RPI) from the Office for Budget Responsibility (OBR) has been used to:

  • deflate disposal cost data (WLGA data, Gate Fees survey and material pricing) from 2022 to 2023 to 2021 to 2022 so they are in line with the year cost data were collected from local authorities
  • inflate all £ per tonne costs from 2021 to 2022 to 2025 to 2026 (year one of EPR for packaging).

For year 2 of EPR for packaging, the year 1 model was not updated further. A further adjustment was then applied to individual and total net local authority costs from 2025 to 2026 to 2026 to 2027 prices using the Consumer Prices Index (CPI) from the OBR.

RPI has been used within the model as it is commonly used to update contracts prices between local authorities and waste management companies. CPI has been applied to the local authority net costs calculated from the model as this index is commonly used across Government, including for inflation targets.

7.Allocation of costs across two tier authorities (England only) 

Costs for different household packaging waste management services are allocated in the model across two tier authorities according to the table below. This follows relevant legislation which assign responsibility for delivery of these services.

Table of costs for different packaging waste management services are allocated in the model across two tier authorities

Local authoritycost Unitary WCA WDA Statutory joint waste partnershipWCA Statutory joint waste partnershipWDA
Collection of dry recycling from kerbside Yes Yes No Yes No
Collection of residual waste from kerbside Yes Yes No Yes No
Bring sites Yes Yes No Yes No
Collection of dry recycling from HWRC Yes No Yes No Yes
Collection of residual from HWRC Yes No Yes No Yes
Transfer stations/bulking and haulage of recyclate Yes No Yes No Yes
Transfer stations/bulking and haulage of residual Yes No Yes No Yes
Tipping away payment n/a No No No No
Handing and sorting of recyclate Yes No(unless we have information that theWCAhas taken responsibility) Yes(unless we have information that theWCAhas taken responsibility) No Yes
Income from recyclate netted off Yes No(unless we have information that theWCAhas taken responsibility) Yes(unless we have information that theWCAhas taken responsibility) No Yes
Treatment and disposal of residual waste Yes No Yes No Yes
Recycling credit n/a No (Value of credit payment toWDAnetted off totalWCApayment) Yes(Where known to pay credits toWCA) No No
Other interauthority payment for waste n/a No No No No

8.Adjustments for recycling credits (England only)

The Environmental Protection Act 1990 requires WDAs to pay waste recycling credit payments to a WCAs in its area when theWCAretains waste for recycling. 

The scheme seeks to ensure that any savings from the reduced waste disposal costs for aWDA(when waste is recycled) are shared with the relevantWCA, and in so doing incentivise recycling for WCAs. 

Unless otherwise agreed[footnote 9], WDAs are obliged to pay recycling credits where claimed by theWCA. ճWDAmust pay theWCAits net saving of expenditure. Where this value is not known the[footnote 10]provide a default value with a 3% indexation.    

A payment of a recycling credit by aWDAfalls under the definition of “disposal costs” for the purposes ofEPRfor packaging and has therefore been included in the assessments of costs. It is also important that producers are not double charged for waste management activities.  If aWDAreceives the disposal costs from PackUK to account for the recycling credits paid to theWCA, theWCAcannot claim the cost of recycling that material as part of its own disposal costs. 

Based on the above,LAPCAP: 

  • pays WDAs to cover the cost of recycling credits for household packaging waste where theWDAis known to pay their WCAs inter-authority payments relating to recycling.  
  • pays no recycling credits to WDAs and Statutory Joint Waste Disposal Authorities where it is known that no recycling credits or similar arrangements are in place    

If recycling credits are paid to aWDAthis has been calculated using the method set out in(using the default payment values set out in the Schedule to the Regulations).  

Contact PackUK if you have been allocated a payment for recycling credits, or if one is netted off your payment, and you either:

  • have no arrangements for paying or receiving a credit but have an adjustment in your notice of assessment letter
  • pay recycling credits and don’t have an adjustment in your notice of assessment letter.

Adjustments for recycling credits will not apply for Statutory Joint Waste Disposal Authorities and Statutory Joint Waste Collection Authorities. 

Calculating recycling credits

Recycling credits are paid for every tonne of household packaging waste collected in the dry recycling scheme. For an example of how recycling credits are calculated in the model please refer to the worked example annex.

9. Supplementary calculation to account for statutory recycling target (Wales only)

The supplementary calculation for local authorities in Wales for year 2 uses:

  • cost data (net of income) reported to the WLGA in 2023/24 for all local authorities in Wales
  • 2023 to 2024 data on municipal recycling rates

A calculation is then made to determine efficient costs in proportion to progress made against the statutory minimum recycling rate. This comparative figure is used to inform an adjustment to the calculation made through the LAPCAP model, to calculate the net efficient disposal costs.

The assumption behind this supplementary calculation is that for local authorities that have met the statutory target, the cost of providing that compliant service (as estimated by cost data provided to the WLGA) is reflective of an efficient service cost, which is necessary to deliver the required outcome.

This adjustment is calculated as follows.

  1. The total amount payable to all local authorities in Wales is calculated, using the methodology in LAPCAP.
  2. Calculate the difference between the 70% statutory requirement and each local authority’s recycling rate.
  3. For local authorities that have met the statutory target recycling rate (70%), efficient disposal costs are assumed to be equal to the cost data provided to WLGA (after adjusting for inflation).
  4. Calculate the sum of payments allocated to all local authorities achieving their statutory recycling target, to determine the remaining amount of funding (“funding shortfall”) that can be distributed amongst those local authorities not achieving their statutory recycling target.
  5. For local authorities that have not met the statutory target recycling rate (70%), payments are calculated as their WLGA costs minus a share of the funding shortfall. This, is proportional to both their original WLGA estimate and their shortfall in actual municipal recycling rate in 2023 to 2024 when compared to the statutory target.
  6. The revised payment total for each local authority in Wales is then compared to the total provisionally calculated in LAPCAP. This is to determine a percentage adjustment to be made.
  7. The percentage adjustment is made to the subtotal calculated through LAPCAP for collection costs, disposal costs, and material income. These totals are then used to calculate the net efficient disposal costs in order to give the total payment amount.

Please refer to the worked examples annex for more detail.

10.Sampledlocal authoritycost data - data collection

In 2023, Defra (supported by 4 contractors) contacted 110local authoritiesto request comprehensive cost information regarding their waste services so that this data could contribute to the build of theLAPCAPmodel for year one.

To ensure as wide and diverse a range as possible, all UK waste collectionlocal authoritieswere put into one of ten socio-demographic groupings. Additionally, they were further separated based on their dry recycling system and the frequency of their residual collections, creating a total of sixty-seven sub-groups for sampling. The table in Annex E displays the number oflocal authoritiesin each group.   

Representative (‘request for information’)RFIsamples were selected from across the groups. Where a local authoritycould not provide data, an alternative similarLAwas approached instead.

All data that was collected and provided was quality assured to ensure accuracy and relevance to the model.  

This process generated 52local authoritydatasets of suitable quality to use in the model. Of these RFIs:

  • 40 are from England
  • 2 from Northern Ireland
  • 5 from Scotland
  • 5 from Wales
  • 19 from WCAs
  • 28 from Unitary Authorities
  • 5 from WDAs

The following list shows local authorities that providedRFIdata:  

  • Armagh Banbridge Craigavon
  • Basingstoke
  • Blackburn
  • Belfast
  • Calderdale
  • Cheltenham
  • Conway
  • Cornwall
  • Derbyshire
  • Dover
  • Dudley
  • East Hertfordshire
  • East Renfrewshire
  • East Riding
  • Edinburgh
  • Fareham
  • Hackney
  • Haringey
  • Harrogate
  • Huntingdon
  • Isle of Scilly
  • Isle of Wight
  • Kirklees
  • Leeds
  • Maldon
  • Neath Port Talbot
  • Newham
  • Newcastle Upon Tyne
  • Norfolk
  • North Ayrshire
  • North East Lincolnshire
  • North West Leicestershire
  • North Yorkshire
  • Plymouth
  • Powys
  • Oldham
  • Orkney
  • Oxfordshire
  • Pembrokeshire
  • Redcar and Cleveland
  • Rhondda Cynon Taf
  • Rotherham
  • Sevenoaks
  • South Ayrshire
  • Stockton-on-Tees
  • Surrey
  • Thurrock
  • Wandsworth
  • Westminster
  • Worthing
  • Wyre

In addition, cost data was provided to the WLGA from all 22 local authorities in Wales. This is based on 2023 to 2024 cost data and adjusted for inflation to 2026 to 2027.

11.Model quality assurance

There are robust processes in place for quality assuring (QA)LAPCAP. This has included close working with the Government Actuary’s Department (GAD) to help develop our overall QA process and undertake model verification.  All outputs were checked against thelocal authoritysample data as well as other data sets such as RO5[footnote 11]and data held by the Welsh government.  

GADhas completed an initial independent verification review of the model which focused on whether implemented calculations:

  • are consistent with the documented methodology
  • are free from error
  • use a logical structure
  • adhere to best practice

The review included the following elements: 

  1. Testing of the model code and underlying functions.
  2. Input and output testing – inputs and outputs have both been provided by Defra, and these have been run through the model to test reproducibility of the results. A detailed code review – all areas of the model that are in scope have been examined thoroughly as part of a “line by line” review. This is intended to identify whether the code meets the specification, is free from error, uses a logical structure, is commented appropriately, and adheres to best practice.  
  3. Independent testing – generating outputs from a completely independent model can provide assurance on the fitness for purpose of the model under review. Results for similar scenarios would be expected to agree within a tolerance based on appropriate judgement. 
  4. Assessing suitability of model documentation for understanding model implementation. 

GAD’s findings, based on the scope ofGAD’s review, show:

  • the model runs without error
  • results are reproduceable
  • they were able to test and independently replicate results

The findings also show room for improvements in our QA process. We have acted upon this feedback andGADhave indicated that since then our QA processes have improved substantially. We have further implemented retro-active QA through regression testing on earlier versions of the model.

GAD’s verification review is based on the model at a point in time and did not cover all aspects of the model.

GAD’s role in verifying the model is not to provide sign off that the model is fully quality assured and fit for purpose, the responsibility for this sits with PackUK.

12.Future updates 

We will shortly be publishing a roadmap which will outline future improvements to the model after year 2.

13.Efficiency and effectiveness 

Under theEPRfor packaging regulations an authority provides an efficient waste management service if the costs of this service are as low as reasonably possible, taking into account:  

  • the waste management service provided by the authority
  • any other factor specific to that authority, or to the area to which it exercises its waste management functions, which in the opinion of PackUK are likely to affect its disposal costs 

Using data received through RFIs and other data sourceslocal authoritiescan be grouped according to similarity of both service provision and local characteristics. PackUK is able to estimate, through averages, what level of expenditure is reasonable forlocal authoritiesin those groups to provide a waste management service for household packaging.

This metric is deemed the lowest reasonable cost for that group.

In Wales, the assessment of net efficient disposal costs also accounts for the impact of meeting the statutory minimum recycling target as further factor. This adjustment seeks to account for the extent to which service costs are optimised to support the attainment of the statutory target.

Effectiveness assessments will not be held in the first year ofEPRfor packaging. 

Regulation 73 of theEPRfor packaging regulations also requires PackUK to carry out its assessments in such a way as to incentivise good environmental outcomes.

By having tonnage-based fees, it incentivises producers to reduce the weight of packaging they put on the market. By not applying a second charge to reused packaging, the system encourages reuse, which helps reduce the amount of packaging that ends up as waste. By netting off an average material value in theLAPCAPcalculations, the system rewards higher-quality materials that are more valuable as recyclate.

14.Modulation  

Disposal fees paid by producers (but notlocal authoritypayments) may change as a result of modulation coming into effect in year 2 ofEPRfor packaging (2026 to 2027) which will further incentivise sustainable packaging decisions and drive recycling rates. The types of packaging which will be subject to higher or lower modulated household packaging waste disposal fees will be based on recyclability assessments in line with the recently publishedRecyclability Assessment Methodology (RAM).

The details of the modulation approach are subject to further design and industry engagement. Changes to disposal fees as a result of modulation will not impact the amount paid toLAs.  

15.Complaints and appeals 

Complaints 

If you have a complaint about the way we operate or the services we provide, please followPackUK’s complaints procedure.

Appeals 

We understand that there may be an occasion where you wish to appeal against a decision that was made by PackUK. Before you can appeal, you must have first brought a complaint underPackUK’s complaints procedure.

If new information or data becomes available relating to your original complaint you may ask for a reconsideration. 

Check PackUK’s appeals procedure for more details onhow to make an appeal.

  1. Recyclatecollection cost includes collection overheads, these come from the Request for Information (RFI) data provided byLAs.Recovery income is reflected in the gate fees module.

  2. This is because the gate fees survey captures the cost incurred at the time of using the facility but does not account for the operational costs of running the facility.

  3. fromRFIdata

  4. The groupings overall (residual and recycling together) account for89%of the cost per tonne variance of our sampled cost data by using those factors.

  5. Local authorities are grouped using aconsensus K-means algorithm, which places each authority into a group based onit’ssimilarity to other authorities acrossall ofthe listed variables.This procedure is done multipletimesand an aggregated group is found.Authorities that share a group do not strictly share identical attributes, but will be moresimilar tothose it shares a group with, than with the authorities in other groups

  6. Recyclatecollection cost includes collection overheads, these come from the Request for Information (RFI) data provided byLAs. Recovery income is reflected in the gate fees module

  7. fromWRAP2021 to 2022

  8. FromLetsRecycle data

  9. (s52 (1B) EPA)

  10. Paragraph 3(6)

  11. RO5 is a category of local authority spending that includes various services, including environmental and regulatory functions