Are the cups you hand out packaging? What EPR means for events

Most conversations about event drinkware stop at the purchase price. Extended producer responsibility moves part of the cost downstream, and the guidance is unusually direct about where cups sit.

Cups are named in the definition

GOV.UK defines packaging as any material used to cover or protect goods that are supplied, and adds that it "includes anything that's designed to be filled at the point of sale, such as a coffee cup".

That is an explicit example rather than an inference. A cup filled when the drink is sold is treated as packaging for these purposes.

Who has to report

The thresholds combine turnover with tonnage.

On the guidance as it stands in 2026, a large producer has annual turnover of £2 million or more and is responsible for supplying or importing more than 50 tonnes of packaging in the UK. A small producer has turnover above £1 million and up to £2 million while supplying more than 25 tonnes, or turnover above £1 million while supplying more than 25 and no more than 50 tonnes.

Below those thresholds the obligation does not bite. Above them, data collection is the first duty: packaging supplied or imported in 2024 was to be reported by 1 April 2025, and data for the 2025 calendar year by 1 April 2026.

What the fees look like

Waste disposal fees apply to large organisations, calculated from reported tonnage of household and commonly binned packaging. Compliance schemes cannot pay them on a producer's behalf.

The published base fees for year one, covering 2025 to 2026, are set per tonne by material: plastic at £423, fibre-based composite at £461, wood at £280, aluminium at £266, steel and other at £259, paper and card at £196 and glass at £192. Fees for packaging placed on the market in 2024 were invoiced from October 2025.

Those rates are published per period, and the next set is already visible. GOV.UK published an illustrative table for year two, covering 2026 to 2027, on 19 December 2025: it moves to a tiered structure by recyclability, with plastic shown between £415 and £545 per tonne depending on the tier, and it states that confirmed year two fees were expected in June 2026. Treat any table as the figures for its own schedule rather than a fixed price list, and check the confirmed year two figures before you budget.

The arithmetic that matters at an event

The comparison people usually run is unit price against unit price. EPR adds a second line to one side of it.

A single-use cup filled at the bar is packaging, and at scale it carries tonnage that counts towards a threshold and a per-tonne fee for the organisations in scope.

Do not assume a reusable cup takes you out of scope. The same guidance lists hiring or loaning out reusable packaging among the activities that make an organisation responsible for packaging, alongside placing goods into packaging and supplying empty packaging. Whether a given reusable cup arrangement is treated as packaging for these purposes is not settled by the pages cited here, so check your own set-up rather than reading a reusable cup as an exemption.

Whether that changes your decision depends on your volumes and on where you sit against the thresholds. It is worth putting the number in the model rather than leaving it out, alongside the deposit and return mechanics that decide how many times each cup actually gets used. If you want the cup side of that model costed, send us your volumes.

Where to check your own position

The three GOV.UK pages listed below are the primary references: who is affected, what the recycling obligations and disposal fees are, and the published base fee table. The thresholds and deadlines change between periods, so read them against the year you are reporting rather than against a summary written for a different one.