EPR Legislation Explained: What New Gel Packaging Costs Mean for Your Cold Chain

For years, temperature-controlled packaging has been a performance conversation focused on thermal efficiency, transit times, and product integrity.

That’s changing.

With the introduction of Extended Producer Responsibility (EPR) for packaging in the UK, cold chain decisions are no longer purely operational. They are financial, regulatory, and increasingly strategic.

And yet, across the food and pharmaceutical sectors, there is still widespread confusion about what EPR actually covers, particularly when it comes to gel-based coolants.

This article addresses the key misunderstandings, explains what’s really changing, and outlines what it means for your cold chain moving forward.

Five Key Takeaways

EPR now includes coolant materials like gel packs; not just outer packaging, significantly increasing reported tonnage and cost exposure.
Many businesses are underreporting due to confusion between EPR and Plastic Packaging Tax (PPT), creating compliance risk.
Gel is typically classified as “other packaging material”, meaning full weight reporting is often required.
Costs are rising without operational changes because the legislation shifts financial responsibility for waste onto producers.
Cold chain optimisation is now a compliance strategy, not just a cost-saving exercise.

Why EPR Matters More Than You Think

At its core, EPR shifts the cost of packaging waste management from local authorities to the businesses that produce it.

That’s not new in principle, but the scope and enforcement now are.

According to DEFRA’s packaging reforms framework, UK producers will be responsible for the full net cost of managing packaging waste, including collection, recycling, and disposal. This represents a fundamental shift in how packaging decisions impact the bottom line.

For cold chain operators, this creates a new reality:

Every component of your packaging system is now under scrutiny
Every gram of material potentially carries a cost
Every reporting decision carries compliance implications

And crucially, coolant materials are not exempt.

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The Biggest Misunderstanding: “It’s Just the Box”

One of the most common assumptions we’re seeing is that EPR only applies to outer packaging like cardboard boxes, liners, and visible plastics.

That’s incorrect.

Under current guidance, all packaging components used to protect, preserve, handle, or deliver goods are in scope. This includes:

Outer cartons
Insulated liners
Phase change materials
Gel ice packs

In other words, if it travels with the product to maintain its integrity, it is likely reportable.

This is where many businesses are unintentionally underreporting, particularly those shipping temperature-sensitive goods at scale.

Gel Packs: Product or Packaging?

Another area of confusion lies in classification.

Many businesses still assume that gel packs, particularly those with specialised formulations, can be treated as part of the product rather than packaging.

In most cases, this assumption doesn’t hold.

Current Environment Agency interpretation generally classifies gel packs as packaging, not product. More specifically, they often fall under the category of “other” materials due to their composite nature.

This creates two challenges:

Full Weight Reporting

Businesses are typically required to report the entire weight of the gel pack, not just the outer film.

That means the internal gel which is often the heaviest component, contributes directly to your EPR liability.

Limited Recycling Offsets

Because gel materials are difficult to recycle, they may attract higher cost obligations compared to more easily recyclable materials like cardboard.

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EPR vs Plastic Packaging Tax: Clearing the Confusion

A significant source of misunderstanding comes from conflating EPR with the Plastic Packaging Tax (PPT).

They are not the same, and treating them as interchangeable can lead to costly mistakes.

Plastic Packaging Tax (PPT)

Applies to plastic packaging with less than 30% recycled content
Charged at a fixed rate per tonne
Focused specifically on material composition

Extended Producer Responsibility (EPR)

Applies to all packaging materials
Costs vary based on recyclability and waste management impact
Focused on end-of-life responsibility

In simple terms:

PPT is about what your packaging is made from
EPR is about what happens to it after use

For gel packs, this distinction is critical. Even if your packaging is compliant with PPT, it may still carry significant EPR costs.

“Why Are Our Costs Increasing?”

This is one of the most frequent questions we hear, particularly from businesses that haven’t changed their packaging or operations.

The answer is straightforward:

The system has changed, not your packaging.

Under EPR, you are now financially responsible for:

Collection of packaging waste
Sorting and recycling infrastructure
Disposal of non-recyclable materials

UK businesses currently cover only a fraction of these costs, with taxpayers funding the majority. EPR reverses that model.

For cold chain users relying heavily on gel-based systems, this often results in:

Higher reported packaging volumes
Increased cost per shipment
Greater scrutiny on material choices

For teams looking to move from reactive fixes to structured optimisation, we also welcome site visits to our facility to review packaging design, testing and risk assessment in practice.

What Do EPR Fees Actually Look Like in Practice?

To move this out of theory and into something tangible, let’s look at a real-world example of how EPR fees are applied to a standard gel ice pack.

When broken down, the cost is not driven by the outer film, it’s overwhelmingly driven by the gel itself.

A Typical 500g Gel Pack: Cost Breakdown

Based on current indicative EPR rates:

Plastic film (13g) is charged at a higher per-tonne rate
Gel polymer (500g) is classified under “other” materials at a lower rate but because of its weight, it dominates the cost

Here’s how that translates:

Plastic film contributes just 0.55p per unit
Gel contents contribute approximately 13.75p per unit
Total EPR cost per gel pack: ~14.3p

Why This Matters

At first glance, 14p may not seem significant. But when scaled across real operations, the impact becomes substantial:

10,000 shipments = £1,430 in EPR fees
100,000 shipments = £14,300
1 million shipments = £143,000

And crucially over 95% of that cost is coming from the gel, not the plastic.

This is where many businesses are caught off guard.

They focus on reducing plastic usage (which is still important), but under EPR, the heaviest component drives the greatest financial exposure and in cold chain packaging, that is almost always the coolant.

The Strategic Implication

This fundamentally changes how packaging decisions should be evaluated.

It’s no longer just about:

thermal performance
unit price
or transit reliability

It’s now also about:

reportable weight
material classification
end-of-life cost liability

In practical terms, this means:

Two packaging solutions with identical performance could carry vastly different long-term costs, purely based on how they are classified under EPR.

Rethinking Coolant: Where Alternatives Like Water Ice Packs Come In

Once businesses understand that coolant weight is driving the majority of EPR cost, the next question is inevitable:

“Is there a more efficient way to achieve the same performance?”

This is where coolant strategy becomes critical.

And for many applications, it opens the door to alternatives such as water-based ice packs.

Why Water-Based Systems Are Back in Focus

Traditionally, gel packs have been the default choice due to their perceived stability and ease of use.

But under EPR, the equation changes.

Water-based systems introduce a different set of characteristics:

Simpler material composition
Clearer classification under EPR
Potentially lower environmental and disposal impact
Opportunity to reduce cost exposure depending on use case

In many scenarios, particularly short-to-medium transit times, they can deliver comparable thermal performance when designed correctly.

But It’s Not a Straight Swap

This is where many businesses go wrong.

Switching coolant is not just about replacing one pack with another.

It requires understanding:

Required temperature range (chilled vs frozen vs controlled ambient)
Transit duration and variability
Product sensitivity
Packaging configuration and insulation performance

In some cases, gel remains the right choice.
In others, water-based systems offer a clear advantage.

The Real Opportunity: System-Level Optimisation

The most effective approach is not choosing between gel or water.

It’s designing a system that uses the right coolant, in the right format, for the right journey.

That may mean:

Using water packs for next-day chilled deliveries
Retaining gel or PCM for longer or more sensitive shipments
Reducing overall coolant volume through better insulation and pack-out design

Because the real optimisation isn’t in the product itself BUT It’s in how the entire cold chain system is engineered.

Small vs Large Producers: Does Size Matter?

EPR obligations vary depending on your organisation’s size and turnover.

Small Producers

New EPR – Phase 1 – £1m T/O + 25t Packaging Waste – Report only (small producers added)

Lower reporting requirements
Reduced financial obligations (in some cases)
Still required to track packaging usage

Large Producers

New EPR – Phase 2 – £2m T/O + 50t Packaging Waste – Pay full EPR fees (large producers)

Full reporting requirements
Full cost exposure
Greater compliance risk

However, one critical point often overlooked:

Growth can quickly move you from one category to another.

Many scaling food brands and D2C pharma businesses are approaching thresholds without realising it, and without systems in place to manage the transition.

The Grey Areas (And Why They Matter)

EPR is still evolving. Guidance continues to be refined, and interpretation can vary.

Key grey areas include:

Classification of gel compositions
Treatment of multi-material packaging
Reporting thresholds and exemptions
Future recyclability criteria

The Environment Agency has already indicated that guidance may continue to change, particularly as data collection improves and infrastructure evolves.

For businesses, this creates both risk and opportunity:

Risk, if you’re reacting late or relying on outdated assumptions

Opportunity, if you’re proactively optimising ahead of enforcement

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What High-Performing Cold Chains Are Doing Differently

The most effective operators are not treating EPR as a reporting exercise.

They’re treating it as a design problem and reengineering their cold chain accordingly.

Because once you understand that cost is now tied to weight, material, and end-of-life impact, the entire system needs to be reconsidered.

Here’s what that looks like in practice:

1. Designing Out Unnecessary Weight Without Compromising Performance

Reducing packaging weight sounds simple. In reality, it’s one of the most misunderstood areas of cold chain optimisation.

What high-performing teams are doing differently is removing excess, not risk.

That means:

Reducing from three gel packs to two, but only after validated thermal testing
Right-sizing packaging based on SKU, not using a single “default” configuration
Aligning pack-out to actual transit lane performance, not worst-case assumptions

The result is not just lower material usage but lower EPR exposure per shipment.

2. Rethinking Coolant Strategy at a System Level

Most businesses treat coolant as a fixed input.

Leading operators don’t.

They are actively reassessing:

Whether gel is the most efficient option for their use case
How coolant weight compares across formats (gel vs water vs PCM)
Whether current pack-outs are over-engineered for real-world conditions

In many cases, the opportunity isn’t switching materials entirely but it’s optimising how and where they are used.

Because under EPR, coolant is no longer just a thermal component.

It is a primary cost driver.

3. Standardising Pack-Out Across Sites and Suppliers

One of the most common, and costly, issues we see is inconsistency.

Different fulfilment centres, teams, or suppliers often introduce small variations in packaging.

Individually, these changes seem insignificant. At scale, they create:

Inaccurate reporting
Increased material usage
Uncontrolled cost creep

High-performing businesses are addressing this by:

Defining clear, standardised pack-out configurations
Aligning all fulfilment locations to the same specifications
Monitoring and controlling substitutions during peak demand

Because if your packaging varies, your costs, and your reporting, will too.

4. Building Packaging Data into Operational Decision-Making

For many organisations, packaging data sits in isolation.

The most advanced teams are integrating it into core decision-making.

They are:

Mapping packaging weight and cost by SKU
Understanding how packaging changes impact margin at an order level
Modelling EPR costs before implementing new packaging formats

This allows them to move from reactive reporting to proactive optimisation.

5. Treating Cold Chain as a Continuous Optimisation Problem

Perhaps the biggest shift is mindset.

High-performing cold chains are no longer static systems.

They are continuously reviewed, tested, and refined — based on:

Seasonal variation
Delivery performance data
Product mix
Regulatory changes

Because under EPR, what worked 12 months ago may no longer be commercially viable today.

The Difference Is Not Complexity

None of these changes are radical in isolation.

What sets leading businesses apart is that they are approaching cold chain design with intent not just inheriting legacy decisions.

And that is where the real opportunity sits.

The Bigger Shift: From Packaging to Strategy

What EPR ultimately signals is a broader shift in the role of packaging within the cold chain.

It is no longer a passive component.

It is an active driver of:

Cost
Compliance
Brand responsibility
Operational efficiency

And gel packs, once a simple, reliable solution, are now at the centre of that conversation.

EPR Is Not Just Another Regulatory Hurdle

EPR is often framed as a compliance exercise.

In reality, it’s a structural shift in how cold chains are evaluated and where cost sits within them.

For businesses relying on temperature-controlled packaging, this is not a marginal change.

It is a rebalancing of the entire system.

Because for the first time:

The heaviest components carry the greatest financial penalty
The least recyclable materials carry the greatest long-term risk
And the least visible parts of your packaging, like coolant, have the greatest impact on cost

The Gap Is Already Starting to Open

Over the next 12–24 months, we will see a clear divide emerge:

Businesses that continue to treat packaging as a fixed operational cost
And those that actively design, measure, and optimise it

The difference will not just be compliance.

It will show up in:

Margin
Scalability
Supplier flexibility
And ultimately, competitiveness

Where Hydropac Fits In

At Hydropac, this is where we add the most value.

Not as a packaging supplier, but as a cold chain optimisation partner.

We work alongside businesses to:

Understand their true EPR exposure
Validate packaging data and classifications
Compare real-world performance across cooling systems
Identify opportunities to reduce cost without increasing risk

Because in this new landscape, success isn’t about reacting to legislation.

It’s about building a cold chain that is fit for what comes next.

Page Summary

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Final Thought

EPR hasn’t made cold chains more complicated.

It has simply made the hidden costs visible.

The question is no longer:

“Is our packaging working?”

It’s: “Is our cold chain designed for the reality we’re now operating in?”

The businesses that can answer that confidently will be the ones that stay ahead.