packaging-check

---
name: packaging-check
description: Produces one dated packaging file for a UK hospitality business - whether the packaging rules oblige you personally or only reach you through your suppliers' prices, which of your packaging lines are banned outright, what the published per tonne fees are for the materials you actually buy, where the plastic packaging tax threshold sits, and the questions to put to each supplier in writing. Use before you renew a packaging supply contract, when a supplier raises prices and blames the regulations, or when you have been told you need to register and do not know whether that is true.
---

# Find out what your packaging actually costs you now, and whether the rules are yours or your supplier's

You give this your packaging lines, what you get through in a year, your turnover band and your supplier invoices. You get back one dated file: whether the extended producer responsibility duties fall on you or reach you only as a price rise, your packaging priced at the published rates by material, the lines that are banned outright with the wording that bans them, where the plastic packaging tax threshold sits relative to you, and a numbered list of what you cannot answer without your suppliers. It does not tell you that you are or are not obligated. That is a determination for the regulator and your accountant, and this file is built so both can see the working.

## What it does

1. **Answer the obligation question first with the two thresholds, because most independent venues fail one of them and everything downstream changes.** GOV.UK sets three conditions that must all be met, and lists them as three bullets: "established in the UK", "supplied or imported more than 25 tonnes of packaging in the UK in the previous year", and "annual turnover worldwide was £1 million or more". Twenty five tonnes is a great deal of packaging for a single site, so a venue over the turnover line very often sits under the tonnage line. Write both numbers into the file with the working, because "we think we're too small" is not a record and a supplier or a landlord will eventually ask for one. Charities have a separate answer: "Charities that supply or import filled or unfilled packaging in the UK are exempt from EPR for packaging requirements."

2. **Work out which packaging activities you actually perform, because the activity decides whose tonnage it is.** The scheme allocates packaging to whoever does the named thing to it, and a hospitality business usually does more than one. You are selling filled packaging to an end user when you hand over a takeaway box. You may be the brand owner if your name is printed on the cup. You may be an importer if you buy direct from outside the UK. You are none of these for a case of wine you serve by the glass, because that packaging was placed on the market by somebody else. GOV.UK's phrasing for the seller activity is "selling filled packaging to an end user (consumer or business)". List each line against the activity and the holder of the obligation. This is the step that turns "we use a lot of packaging" into a tonnage that is legally yours and a larger tonnage that is not.

3. **If both thresholds are met, settle small against large, because the duties differ by more than the label suggests.** The table is exact, and the top right cell surprises people: under 25 tonnes is no obligation at any turnover; 25 to 50 tonnes is a small producer at any turnover above £1 million; and over 50 tonnes is a small producer between £1 million and £2 million turnover but a large producer above £2 million. A small producer must register with the environmental regulator, "report packaging data every year", and keep the data for seven years. A large producer must do all of that, "report packaging data every 6 months", obtain recycling notes, submit compliance certificates annually, and "pay a waste disposal fee for any household packaging to PackUK each year". The fee is the large producer's cost. A small producer reports and does not pay it.

4. **Price your packaging at the published rates whichever side of the line you are on, because that is the number moving inside your supplier invoices.** The confirmed base fees for 2025 to 2026, in pounds per tonne, are: aluminium £266, fibre-based composite £461, glass £192, paper and card £196, plastic £423, steel £259, wood £280, and other £259. Those fees "will cover PackUK costs and provide local authorities with additional income to cover the cost of recycling and disposal of waste packaging materials". Multiply your annual tonnage per material by that rate and you have the sum sitting inside your supply chain whether or not it appears on your bill. Fibre-based composite is worth looking at twice: at £461 a tonne it is the dearest material in the table, and a coffee counter usually holds more of it than anyone realised.

5. **Sort the same lines by recyclability rating, because from the 2026 to 2027 financial year the rating multiplies the fee.** Under the Recyclability Assessment Methodology each item is rated, with "red being the least recyclable and green being the most recyclable". PackUK's modulation statement is careful about what this does and does not do: "The modulation of household packaging waste disposal fees will not increase the total of all household packaging waste disposal fees paid. Instead, it will affect how these costs are allocated by material." The red multiplier escalates over three years, 1.2 in 2026 to 2027, 1.6 in 2027 to 2028 and 2.0 in 2028 to 2029. The illustrative Year 2 figures show the spread inside one material: plastic at £415 green, £455 amber and £545 red per tonne. Those are illustrative and must be labelled as such, because the page says "The fees are subject to change as more information becomes available" and that "Confirmed fees for Year 2 are expected to be published in June 2026". Check whether the confirmed figures have since appeared before you quote any of them.

6. **Check the plastic packaging tax separately, because it is a different tax with a different threshold and people conflate the two.** You need to register if you "expect to import into the UK or manufacture in the UK 10 tonnes or more of finished plastic packaging components in the next 30 days" or "have imported into the UK or manufactured in the UK 10 tonnes or more of finished plastic packaging components in the last 12 months". The tax bites on components that "contain less than 30% recycled plastic", and the rate is "£228.82 per tonne from 1 April 2026". A restaurant buying boxes from a UK supplier is neither importing nor manufacturing them, so the tax is the supplier's to register for and yours to see in the price. A venue importing its own branded packaging from overseas is in a different position and should put that volume in front of its accountant.

7. **Check the single-use plastics ban, which applies to you at any size and has no turnover test at all.** In England four things are banned with no exemptions: "drinks stirrers", "balloon sticks", "cutlery", and "food and drink containers made of expanded and extruded polystyrene". Plates, bowls and trays are banned for supply to the public but permitted where "the items are packaging, pre-filled or filled at the point of sale", and the published example is exactly a hospitality one: "a plate filled at the counter of an establishment selling ready-to-consume food, such as a takeaway, bakery, canteen or public house". So the same plastic plate is lawful filled at your counter and unlawful handed over empty. Enforcement is local and physical: "Local authorities will carry out inspections to make sure the rules are being followed", including test purchases, and "If you break the law, you could be fined and ordered to cover the cost of the investigation."

8. **Ask your suppliers the three questions in writing, because your own data is worthless without theirs.** For each packaging line: what does one unit weigh, what material is it under the scheme's own categories, and what recyclability rating does it carry. Without unit weights you cannot convert cases into tonnes and every figure in steps 4 and 5 is a guess. Without the material category you will price a fibre-based composite cup as paper and card and understate it by £265 a tonne at the Year 1 rates. Record who you asked, when, and what came back. A supplier who cannot answer the weight question is telling you something about whether their own reporting is real.

9. **Build the register, date it, and diary the dates that will change it.** One row per packaging line: description, supplier, material category, unit weight, annual units, annual tonnage, the fee rate applied and its source, the recyclability rating if known, and whether the line is banned, exempt or unaffected. Date the file and record when each source was read. Three dates go in the diary: the confirmed Year 2 fees, the 1.6 red multiplier from the 2027 to 2028 year, and your own next reporting deadline if you turn out to be obligated. Fee schedules here are reissued every year, and a packaging register with no date on it will be quoted with confidence eighteen months after it stopped being true.

## Then it checks

1. The file states the annual packaging tonnage and the worldwide turnover as separate numbers with the working behind each, and reaches the obligation question through both rather than through one.
2. Every packaging line is assigned to a named activity with the holder of the obligation identified, and no line is left without one.
3. Every fee rate in the file is labelled either confirmed or illustrative, carries the year it applies to, and names the page it was read from with the date of reading.
4. No illustrative Year 2 figure is presented as a confirmed fee, and the file records whether confirmed Year 2 fees had been published at the time it was built.
5. The plastic packaging tax section states whether the business imports or manufactures finished plastic packaging components at all, and does not apply the 10 tonne threshold to packaging merely bought from a UK supplier.
6. Every banned item on the premises is listed with the wording that bans it and the exemption tested against it, and the file states nowhere that the business is compliant, obligated or exempt as a matter of law.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is. A letter asking a supplier for unit weights goes out over the name of the person who will have to read the reply.
- Never tell an owner they are an obligated producer, that they are exempt, or that they need to register. Those are determinations for the environmental regulator and the owner's accountant, and an owner told "you are fine" stops asking the people who could actually tell them.
- Refuse to present an illustrative fee as a confirmed one, and refuse to carry any fee figure forward into a later file without re-reading the page it came from. Every rate in this area has been reissued at least once.
- Never estimate a unit weight in order to complete a tonnage. A missing weight is a gap with a supplier's name against it, not a number with a shrug behind it.
- Never state a benchmark for how much packaging a venue of a given size uses, a typical annual fee, or a percentage saving from changing material. No published figure exists for a single independent UK venue, and an owner who budgets from a borrowed number will conclude their own site is failing.
- Never treat a supplier's statement that fees are "included" or "already covered" as established. Record who said it and on what date, and leave it as an open question until an invoice line or a written confirmation arrives.
- This output is a working document prepared for the owner to check with their accountant, their packaging suppliers and their environmental regulator or local authority trading standards team before it is relied on. It gathers published thresholds and fee rates, records what the site buys and names the gaps. It is not tax advice and it does not certify compliance with anything.

## Built from
- GOV.UK, "Extended producer responsibility for packaging: who is affected and what to do", https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do, published 7 June 2022, last updated 19 August 2026, read 16 September 2026: the three threshold conditions in step 1, the charity exemption, the seller activity wording in step 2, and the full small against large table with the differing duties in step 3.
- GOV.UK and PackUK, "Extended Producer Responsibility for Packaging: 2025 base fees", https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-2025-base-fees/extended-producer-responsibility-for-packaging-2025-base-fees, updated 30 June 2025, read 16 September 2026: the confirmed 2025 to 2026 per tonne rates for all eight materials and the statement of what the fees cover, in step 4.
- GOV.UK and PackUK, "Year 2 illustrative waste disposal fees: Extended producer responsibility for packaging", https://www.gov.uk/government/publications/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging, updated 19 December 2025, read 16 September 2026: the green, amber and red illustrative rates per material, the warning that the fees are subject to change, and the June 2026 publication expectation, all in step 5.
- GOV.UK and PackUK, "PackUK extended producer responsibility (EPR) for packaging: producer disposal fees modulation statement", https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement, published 28 June 2025, last updated 17 February 2026, read 16 September 2026: the red, amber and green ratings, the statement that modulation reallocates rather than increases the total, and the 1.2, 1.6 and 2.0 escalation with its years, in step 5.
- HMRC and GOV.UK, "Check if you need to register for Plastic Packaging Tax", https://www.gov.uk/guidance/check-if-you-need-to-register-for-plastic-packaging-tax, published 4 November 2021, last updated 12 February 2026, read 16 September 2026: the 10 tonne registration tests, the 30% recycled plastic threshold and the rate of £228.82 per tonne from 1 April 2026, in step 6.
- GOV.UK, "Single-use plastics ban: plates, bowls, trays, containers, cutlery and balloon sticks", https://www.gov.uk/guidance/single-use-plastics-ban-plates-bowls-trays-containers-cutlery-and-balloon-sticks, published 22 January 2024, last updated 7 October 2024, read 16 September 2026: the items banned with no exemptions, the filled-at-the-counter exemption with its hospitality example, the polystyrene rule, and the local authority inspection and costs wording, all in step 7.

This is a working document prepared for the owner to check with their accountant, their packaging suppliers and their regulator before it is relied on. It is not tax advice and it does not certify compliance.

# packaging-check

## You are given
One UK hospitality business's packaging position, already judged by Claude. Specifically: the business name, its legal form and whether it is a charity; its worldwide annual turnover for the stated year with the source of that figure; a line by line list of every packaging item it buys or supplies, each carrying a description, the supplier, the pack or case size, the units bought in the stated year, the unit weight in grams where a supplier has given one, the material category, and the recyclability rating where one has been supplied; Claude's judgement for each line of which packaging activity applies and who holds the obligation; Claude's judgement of whether the business imports or manufactures finished plastic packaging components at all; the published fee rates Claude is applying, each labelled confirmed or illustrative with its year and source URL; the recyclability modulation factors and their years; the list of banned single-use plastic items and the exemption wording; and every supplier question asked with the date asked and the answer received. Where a judgement or a figure is missing it arrives as the words `not supplied`.

## Produce
Write into a `./packaging-check-output/` folder:

1. `threshold-test.csv` with these columns in this order: `business_name`, `is_charity`, `turnover_year`, `worldwide_turnover_gbp`, `turnover_source`, `annual_packaging_tonnes`, `tonnage_method`, `lines_with_supplied_weight`, `lines_with_missing_weight`, `established_in_uk`, `producer_class_indicated`, `source_url`, `source_read_date`. One row. `producer_class_indicated` is exactly one of `no obligation indicated`, `small producer indicated`, `large producer indicated`, `not supplied`, and is copied from the input and never derived. `tonnage_method` is exactly one of `all weights supplied`, `partial weights supplied`, `no weights supplied`.
2. `packaging-lines.csv` with columns: `line_ref`, `description`, `supplier`, `material_category`, `units_per_year`, `unit_weight_grams`, `weight_source`, `annual_tonnes`, `activity`, `obligation_holder`, `recyclability_rating`, `banned_status`. `line_ref` is P001 upward. `material_category` is exactly one of `aluminium`, `fibre-based composite`, `glass`, `paper and card`, `plastic`, `steel`, `wood`, `other`. `activity` is exactly one of `brand owner`, `packer or filler`, `importer`, `distributor`, `seller to end user`, `online marketplace`, `service provider`, `not an activity of this business`, `not supplied`. `recyclability_rating` is exactly one of `green`, `amber`, `red`, `not supplied`. `banned_status` is exactly one of `banned with no exemption`, `permitted under the filled at point of sale exemption`, `not affected`, `not supplied`. `weight_source` is exactly one of `supplier stated`, `weighed on site`, `not supplied`, and `annual_tonnes` is left empty wherever `weight_source` is `not supplied`.
3. `fee-exposure.csv` with columns: `material_category`, `annual_tonnes`, `fee_year`, `fee_status`, `fee_rate_gbp_per_tonne`, `rating_applied`, `modulation_factor`, `exposure_gbp`, `source_url`, `source_read_date`. `fee_status` is exactly one of `confirmed` or `illustrative` and is never blank. `modulation_factor` is `1.0` unless a factor was supplied for that year and rating. `exposure_gbp` is `annual_tonnes` multiplied by `fee_rate_gbp_per_tonne` multiplied by `modulation_factor`, to two decimal places, and is left empty wherever `annual_tonnes` is empty.
4. `plastic-packaging-tax.csv` with columns: `imports_finished_components`, `manufactures_finished_components`, `tonnes_last_12_months`, `tonnes_expected_next_30_days`, `threshold_tonnes`, `recycled_content_threshold_percent`, `rate_gbp_per_tonne`, `rate_effective_from`, `registration_question_open`, `source_url`, `source_read_date`. One row. `threshold_tonnes`, `recycled_content_threshold_percent`, `rate_gbp_per_tonne` and `rate_effective_from` are copied exactly from the input. `registration_question_open` is `yes` or `no`.
5. `banned-items.csv` with columns: `line_ref`, `description`, `item_type`, `banned_wording_verbatim`, `exemption_tested`, `exemption_wording_verbatim`, `outcome`. One row for every line whose `banned_status` is not `not affected`. `outcome` is exactly one of `remove from use`, `permitted as currently supplied`, `needs a decision by the owner`, `not supplied`.
6. `supplier-questions.csv` with columns: `supplier`, `line_refs`, `question`, `date_asked`, `asked_by`, `date_answered`, `answer_verbatim`, `status`. `question` is exactly one of `unit weight in grams`, `material category under the scheme`, `recyclability rating`. `status` is exactly one of `answered`, `asked and not answered`, `not yet asked`.
7. `gaps.md` - a numbered list of: every line with no supplied unit weight and the supplier it belongs to; every line with `not supplied` in any judgement column; every fee rate used that is `illustrative`, naming the date confirmed figures are expected; every banned item with outcome `needs a decision by the owner`; every supplier question with status `asked and not answered` and how many days have passed; any missing source URL or read date; and the three diary dates.

## Rules
- Codex measures, converts, prices and records. It never invents, never assigns a packaging activity that was not supplied, never rewords a supplier's description or a published fee, and never makes the obligated producer judgement that was supplied to it.
- Never estimate, infer or substitute a unit weight. A line with no supplied weight has an empty `annual_tonnes` and an empty `exposure_gbp`, and appears in `gaps.md`. Filling the gap with an assumption is the one thing that would make every figure in `fee-exposure.csv` wrong at once.
- Never write `confirmed` into `fee_status` for a rate the input labelled illustrative, and never write an illustrative figure into any summary sentence without the word illustrative beside it.
- Never state that the business is an obligated producer, is exempt, must register, or complies with anything. None of these goes into any file.
- Never apply the plastic packaging tax threshold to packaging the business merely buys from a UK supplier. Where both `imports_finished_components` and `manufactures_finished_components` are `no`, the tonnage columns are left empty and `registration_question_open` is `no`.
- Never write a benchmark, an industry average, a typical annual packaging spend or tonnage, or a percentage saving from switching material. No such figure exists for a single independent UK venue and none is to appear in any file.
- Never record a threshold, a rate or a ban without its source URL and the date that source was read, both copied from the input.
- A rule or a rate that has not yet commenced is recorded with its start date and is never applied to a current year figure.
- Use British English, GBP for money and DD Month YYYY for every date. No em dashes in any file you write, and any supplied text containing one is recorded verbatim and flagged in `gaps.md`.
- Every file ends with this line: this is a working document prepared for the owner to check with their accountant, their packaging suppliers and their regulator before it is relied on; it is not tax advice and it does not certify compliance.

## Return
The absolute path of each file written, the row count of each CSV, the worldwide turnover and annual packaging tonnage as recorded with the tonnage method, the producer class as supplied, the number of lines with a supplied unit weight against those without with the suppliers named, the total fee exposure by material split into confirmed and illustrative subtotals, the single largest material by exposure, the count of lines by recyclability rating including `not supplied`, whether the plastic packaging tax registration question is open and why, every banned item found with its outcome, the number of supplier questions answered against those outstanding with the oldest date asked, and the `gaps.md` item count.