Short answer: yes, in effect. A bubble mailer is assessed on its construction, and because it contains a bonded plastic layer, it's treated as plastic or as a paper-plastic composite — not as plain paper. Both sit in higher EPR fee categories than a single-material paper mailer.
EPR fees depend on what packaging is made of
Under the UK's Extended Producer Responsibility (EPR) scheme, businesses that place packaging on the market pay fees based on the material — and different materials carry very different fees per tonne. Paper and card sit among the lowest. Plastic is higher. Fibre-based composite — packaging that combines paper or board with another material like plastic — is higher still, near the top of the range.
So the category your packaging falls into directly affects what you pay. And packaging is judged on what it's actually made of, not on what it looks like or what you'd call it.
Where a bubble mailer lands
A bubble mailer combines an outer layer with a bonded plastic bubble lining. How it's classified depends on its construction:
- A plastic bubble mailer (plastic outer, plastic bubble) is plastic — and reported, and charged, as plastic.
- A paper-outer bubble mailer (paper outside, plastic bubble inside) is a combination of paper and plastic. Because the layers are bonded and can't be separated by hand, it's assessed together as one item — a fibre-based composite — rather than as the paper it resembles.
Either way, a bubble mailer doesn't get the low paper-and-board fee. The plastic content is what determines its category, and that pushes it into a higher-fee bracket than a plain paper mailer.
Why "but it's mostly paper" doesn't help
It's a reasonable question: if a bubble mailer is mostly paper by appearance, why isn't it treated as paper?
The answer is in how composite packaging is assessed. For fibre-based packaging, there's a plastic-content threshold: keep the plastic low enough and it's assessed as paper and board; above that level, it's assessed as a fibre-based composite. A bubble mailer's plastic bubble layer is a substantial part of the product — well above the threshold — so it doesn't qualify for the paper treatment. The bonded plastic is doing exactly what pushes the mailer into the higher-fee category.
The plastic packaging tax angle
There's a second cost worth knowing about. Separate from EPR, the UK Plastic Packaging Tax applies to plastic packaging that doesn't contain enough recycled content. A plastic bubble mailer can fall within scope of that tax as well as its EPR fee — so an all-plastic mailer can attract costs on two fronts. (The exact recycled-content threshold and rate are set by HMRC and change periodically, so check the current figures.)
The lower-fee alternative
The reason a bubble mailer costs more is the plastic. Remove it, and the picture changes.
A mono-material paper mailing bag is a single material — paper — with no bonded plastic layer. That means it's assessed as paper and board, the lowest-fee mainstream category, and it's recyclable in the standard kerbside paper stream. For semi-fragile items, a padded paper mailer uses cushioned paper instead of plastic bubble, so it does the same job without the higher-fee plastic content.
For a business sending volume, moving mailers from bubble to paper shifts that weight out of the plastic or composite category and into the paper one — which is one of the simplest ways to reduce what you pay as EPR fees rise through 2026.
So, do bubble mailers count as plastic?
For EPR purposes, a bubble mailer is treated according to its construction — as plastic, or as a paper-plastic composite — and both carry higher fees than plain paper. If lowering your fees matters, a single-material paper mailer avoids the plastic content that drives the higher category.
Frequently asked questions
Are bubble mailers classed as plastic packaging? A plastic bubble mailer is reported as plastic. A paper-outer bubble mailer is a bonded paper-plastic composite, assessed as one item rather than as paper. Neither gets the low paper-and-board fee.
Do bubble mailers pay higher EPR fees than paper mailers? Yes. Plastic and composite sit in higher fee categories than paper and board, so a bubble mailer generally costs more per tonne than a single-material paper mailer.
Are paper bubble mailers still counted as plastic? If the paper outer and plastic bubble are bonded and can't be separated by hand, the mailer is assessed as a composite — not as plain paper — because the plastic content is above the threshold for paper treatment.
How do I lower the EPR fee on my mailers? Switch to a single-material paper mailer. Removing the plastic bubble layer moves that weight into the lower-fee paper category and makes the mailer recyclable in the kerbside paper stream.
Explore the full EPR packaging range
Every product below is chosen to help lower your EPR fees — by switching to a lower-fee material category, cutting weight, or keeping packaging a single recyclable stream. Start with the EPR-friendly packaging hub for how the fees work, or go straight to a product family:
- Mono-material mailing bags — paper mailers that replace two-material bubble-lined bags, assessed as a single paper component.
- Paper protective packaging & void fill — paper void fill, bubble wrap and honeycomb that replace plastic, recycled in one paper stream.
- Recyclable cardboard boxes — the lowest-fee mainstream material, with SMART fluting to cut weight without losing strength.
- Paper tape & closures — gummed paper tape that seals boxes and recycles with them as one fibre stream.
- Lightweight stretch film — thinner, stronger film that puts less plastic by weight on every pallet.
Not sure where the biggest saving is? Send us your current packaging and we'll model it.
Do Bubble Mailers Count as Plastic for EPR Fees?