How to challenge a packaging EPR liability notice
Identify the disputed calculation or liability, gather supporting records, contact PackUK and complain through the reporting portal before appealing. Lodge a fee appeal within 2 months of complaint resolution. Keep payments on schedule while seeking clarification. Cambridge China Bridge can help collect factory packaging evidence.
Identify the error and build an evidence file
Save the notice and the packaging submission used to prepare it. Mark each disputed entry and explain whether your concern is liability, packaging weight, material classification or arithmetic. For background on whether your business is covered, read our packaging EPR guide.
Prepare a reconciliation showing the reported entry, your proposed correction, the reason and the supporting document. Useful records include component weights, weighing photographs, supplier specifications, shipment quantities and records of packaging changes. Match factory documents to the goods and reporting period concerned. Our packaging reporting file guide helps organise this trail.
Contact PackUK, then make the formal complaint
First contact PackUK’s customer support desk to discuss the issue. For a disputed fee, the notice guidance requires a complaint through the report packaging data portal before an appeal. You cannot go straight to a tribunal.
Give the notice reference, the disputed entries, your explanation and the correction you want. Attach the reconciliation and supporting records. Ask for an acknowledgement, a complaint reference and a written outcome confirming when the complaint process is complete. Keep copies of submissions and correspondence.
Appeal the fee decision within the deadline
After completing PackUK’s complaints process, you can appeal on the grounds that you are not liable for a disposal or administration fee, or that the assessed amount has been miscalculated. Lodge the appeal within 2 months of the date your complaint is resolved.
Use the body for your organisation’s location shown below. Assemble the notice, complaint outcome, evidence and a clear explanation of the decision you dispute. Record the resolution date immediately and obtain the receiving body’s filing instructions.
| Organisation location | Appeal body |
|---|---|
| England or Wales | First-tier Tribunal, General Regulatory Chamber |
| Scotland | The sheriff |
| Northern Ireland | Planning Appeals Commission |
Keep payment dates separate from the dispute
GOV.UK requires payment by the dates on your notice and continued payment of the current amounts even if you expect a recalculation. Do not assume that submitting a complaint or appeal pauses collection. Ask PackUK to clarify the payment position in writing and keep finance informed.
If a recalculation reduces your liability, PackUK updates the notice and tells you whether you can request a refund through the reporting portal. The original payment dates remain unchanged. Keep the revised notice, payment records and any refund request together.
Do not confuse data corrections with an appeal
PackUK’s announcement set 1 September 2026 as the cut-off for corrections to 2025 packaging data to affect notices. Later resubmissions do not affect notices or disposal fees, although producers must continue correcting data for their recycling obligations. Do not rely on a late data resubmission alone to change the bill; raise the disputed decision with PackUK.
Ask your reporting adviser to distinguish a submission error from a fee calculation error. Where household classification is disputed, use our household and non-household packaging guide to structure your review. Cambridge China Bridge’s staff in China can help obtain packaging specifications and component-weight evidence from factories.
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Treat a penalty notice as a separate challenge
A variable monetary penalty has a different appeal route: you do not have to complete PackUK’s complaints process first. The penalty appeal deadline is 2 months from the date PackUK sent the decision notice. In Scotland, this appeal goes to the Scottish Ministers, rather than the sheriff.
The penalty is suspended while its appeal is decided. Keep that suspension separate from the underlying fee payment schedule. Save the penalty notice and dispatch date, and obtain advice promptly if you receive it alongside a disputed liability notice.
Frequently asked questions
Can I appeal a packaging EPR bill straight away?
For a fee liability dispute, first contact PackUK and complete its complaint process through the reporting portal. You cannot go directly to a tribunal.
How long do I have to appeal an EPR liability notice?
Lodge a fee appeal within 2 months of the date your PackUK complaint is resolved. Save the written outcome and record that date.
Can I stop paying while I dispute the EPR notice?
Do not assume the challenge pauses payment. Follow the notice’s dates and seek written clarification from PackUK. GOV.UK says to keep paying current amounts even if you expect a recalculation.
What evidence should I send with an EPR complaint?
Send the notice, relevant packaging submission and a reconciliation of each disputed entry. Support corrections with component weights, supplier specifications, shipment records and dated packaging-change records.