UK EPR 2027-28: why a bubble-lined paper mailer may pay 1.6 times the fee

A bubble-lined paper mailer looks like the sensible middle choice. Paper on the outside, a little bubble film inside for protection, and it says "paper" to the customer.

Under UK packaging EPR, it lands in the most expensive band.

PackUK's recyclability methodology lists "padded polyethylene lined envelopes" as red. Red-rated household packaging pays 1.6 times the base disposal fee in the 2027-28 fee year, and 2.0 times in 2028-29. A plain plastic bubble mailer is not much better off. An all-paper padded mailer can be rated green, but it has its own trade-offs.

Checked against official sources on 28 October 2026.

A note on where I stand. We make plastic courier bags and paper cushioning in Jaipur, and the UK is one of our export markets. So we have products on both sides of this question, and I would rather you choose with the real rules in front of you.

How do UK packaging fees work?

You only pay disposal fees if you are a large producer. The gov.uk guidance Check if you must comply with EPR for packaging (updated August 2026) sets the lines:

1. Large producer: more than GBP 2 million annual turnover and more than 50 tonnes of packaging supplied or imported a year. Large producers pay a waste disposal fee for household packaging every year.
2. Small producer: GBP 1 million or more turnover and more than 25 tonnes, without crossing both large-producer lines. Small producers register and report, but do not pay the disposal fee.

Mailers sent to consumers count as household packaging. The gov.uk guidance on what to report as a large producer names cardboard boxes, carrier bags, bubble wrap and mail bags as examples of shipment packaging.

The fee is charged per tonne, by material, and then adjusted by the pack's recyclability rating:

1. Amber is the base fee.
2. Red pays a multiple of it: 1.2 in 2026-27, 1.6 in 2027-28 and 2.0 in 2028-29.
3. Green gets a discount, paid for by the red surcharge, so the total collected does not change.

These factors are in the PackUK modulation statement (updated February 2026). Strictly, the multiple applies to the household disposal part of the fee, which the statement calls a significant component of the base fee.

Why is a bubble-lined paper mailer red?

Because the rating rules say so, by name.

The PackUK RAM 2027 materials guidance (updated August 2026) lists "padded polyethylene (PE) lined envelopes" as red at the collection stage. It appears under paper and board, and again under fibre-based composites. A red result at any stage makes the whole pack red.

The older version, RAM 1.1, which applies to packaging supplied in 2026, also lists them as red, but with the words "unless easily separated by hand". The 2027 list carries no such exception. If your mailer's lining peels out cleanly, that may have helped for 2026. Do not count on it for 2027.

Think of a thali. Rice and dal served side by side can each be finished. Pour the dal over the rice and you cannot take it back.

A bubble lining glued to paper is the dal on the rice.

There is a second question: which material fee applies? RAM says paper or board with more than 5% plastic by mass must be assessed as a fibre-based composite. Fibre-based composite has a higher fee per tonne than paper.

I would weigh one before reading any further. You can check this yourself in five minutes:

1. Weigh one mailer on a kitchen scale.
2. Peel out the bubble lining and weigh it.
3. Divide the lining weight by the total. If it is more than 5%, the mailer is assessed as fibre-based composite.

What does 1.6 times mean in pounds?

The honest answer: nobody can tell you yet. PackUK had not published any 2027-28 fee figures as of 28 October 2026.

What we have is the illustrative table for Year 2, the 2026-27 fee year, which PackUK last updated in December 2025. These are illustrative Year 2 figures, not final and not Year 3:

In Year 2, red is 1.2 times amber. In Year 3 the factor becomes 1.6. I will not multiply these Year 2 numbers by 1.6 for you, because the Year 3 base fees will be different. When PackUK publishes them, take the amber figure for your material and multiply by 1.6.

For me, the next detail matters more than the fee table. The Year 2 fees were calculated on packaging supplied in 2025. On that pattern, the 2027-28 bill rests on what you supplied in 2026, rated under RAM 1.1. What you ship in 2027 is rated under RAM 2027 and feeds the 2028-29 bill, where red pays 2.0 times. Check this with your compliance scheme. But if I am right, the mailer you choose for 2027 is the one that meets the highest factor.

Is a plastic bubble mailer any better?

Not by much. RAM 2027 puts envelopes and bags made of flexible plastic in its "plastic (flexibles)" group. That group cannot be rated green at present. It is red, unless it goes through a take-back scheme that meets the RAM evidence rules at each stage, in which case it can be amber.

An all-plastic mailer has a second cost. If plastic is the heaviest material in it, it is a plastic packaging component for the UK Plastic Packaging Tax. Below 30% recycled plastic it pays GBP 228.82 a tonne now, and GBP 236.56 a tonne from 1 April 2027 as announced at Budget 2026. HMRC's tax scope guidance explains the heaviest-material test.

A bubble-lined paper mailer escapes that tax if paper is the heaviest material in it. So the two options that contain plastic trade one cost against another. Weigh yours to know which side it falls on.

And an all-paper padded mailer?

Paper and board is the only option in this comparison that can be rated green in 2027. RAM 2027 sets conditions:

1. No glitter, wax or silicone coating on the paper.
2. Non-paper content up to 10% by weight for green at the reprocessing stage. Above 10% it is amber, above 15% red.
3. At least 40 mm in two dimensions, which any mailer is.
4. No automatic red flags: inks not made under the European Printing Ink Association's exclusion charter, or more than 1 ppm of total PFAS, both turn a pack red.

The trade-offs are real, and I would test them before switching:

1. Fees are per tonne. A heavier paper mailer at a green rate can still cost more in total than a lighter one at a red rate. Do the sum with your own weights.
2. Protection. Paper padding cushions differently from bubble film. Pack real orders and drop them, as in our warehouse drop test.
3. Rain and damp. Leave a few packed mailers somewhere damp for a day and see how they hold up.

Our article on bubble wrap in a poly mailer for international post covers when a mailer is enough protection at all.

A worksheet for comparing mailers

Fee per 1,000 mailers, in pounds = grams per mailer x fee per tonne / 1,000.

Let us take an example with a made-up weight. A 30 g mailer at the Year 2 illustrative red fee for fibre-based composite (GBP 630 a tonne) works out at GBP 18.90 per thousand mailers. At the Year 2 illustrative green fee for paper, the same weight comes to GBP 5.70.

Now put in your real weights. When PackUK publishes the Year 3 fees, put those in too.

What to ask your mailer supplier

RAM puts the burden of proof on the producer. Without evidence for green or amber, a pack must be reported as red, and the guidance tells producers to go to their supplier for missing details. So ask for:

1. The weight of one mailer, and the weight of each material in it.
2. The plastic share by mass, against the 5% line.
3. Whether the lining separates by hand.
4. Confirmation that the inks are made under the EuPIA exclusion charter.
5. A PFAS statement against the 1 ppm limit.
6. Recycled plastic content, with evidence, if the mailer is mainly plastic.

What to do in 2027

1. Weigh every mailer type you use, and work out the tonnes per year for each.
2. Check if you are a large producer under the gov.uk thresholds.
3. Rate each type under RAM 2027, with your supplier's evidence on file.
4. Trial an alternative for your highest-volume red mailer, with drop tests and a damp test.
5. Watch PackUK for the Year 3 fee figures, and put them into the worksheet.
6. Decide before your 2027 volumes build up, because those volumes may feed the 2.0 factor.

If you want a second opinion, send us a sample of the mailer you use now. We will weigh it, split it by material, and tell you which way the rules are likely to rate it.