The FPA Friday Digest
02 October 2026
This week’s Digest leads on PackUK’s first full annual report, which provides the clearest picture yet of the first year of pEPR financial operation. The report sets out £1.41bn collected in packaging waste disposal fees, £1.34bn paid to local authorities and further detail on the £102m government top-up, alongside the scheme’s administration costs and the December direct-debit error.
We also look at further signs that the UK Deposit Return Scheme is moving firmly from policy design into delivery, with Exchange for Change opening the first phase of registration, publishing new transition arrangements for pre-DRS stock and confirming the collection and processing network that will support the scheme from October 2027.
Elsewhere, new evidence from North Somerset highlights both the potential of kerbside flexible-plastics collections and the practical infrastructure challenges that come with them.
Across Europe, member states are seeking a more targeted approach to the burden PPWR EPR requirements could place on smaller producers, while Italy moves to preserve specified compostable foodservice packaging formats under PPWR flexibility. We also look at the EU’s new green-claims rules, which place greater emphasis on evidence-based environmental claims made on products and packaging entering European markets. And we cover developments in food-grade recycled PP and the latest international moves on PFAS in food packaging.
In FPA news, Louisa Goodfellow of Ecosurety takes over as chair of the Sustainability & Government Affairs Committee, while recent FPA commentary continues to gain media attention.
PACKAGING REFORMS UPDATE
PackUK annual report sets out first full year of pEPR
PackUK collected £1.41bn in packaging waste disposal fees and paid £1.34bn to local authorities during the first full year of extended producer responsibility for packaging, according to its newly published annual report.
The report, published on 30 September, covers the year to 31 March 2026 and provides the fullest official account so far of the scheme’s first year of financial operation. PackUK says £18.7m was used to fund scheme administration, while £37m remained as a refund liability and an expected credit loss provision of £17m was recorded.
It also explains the circumstances behind the £102m of additional funding provided by Defra during the first year. PackUK initially expected to raise £1.523bn, including local-authority payments, administration and an impairment provision. Initial Notices of Liability raised £1.46bn, but subsequent producer data resubmissions reduced obligated packaging tonnage. PackUK says Defra provided £102m on an exceptional basis to avoid recalculating producer fees and ensure local authorities received their full expected funding.
The report also quantifies the direct-debit error that occurred in December 2025. Approximately 11% of obligated producers were affected, with £143m taken in excess before refunds were issued.
Looking ahead, PackUK says work is under way to develop assessments of the efficiency and effectiveness of local-authority waste-management services, with those assessments to be introduced no later than 2028. Its five-year strategy, setting objectives through to 2031, is due later this year.
FPA comment:
“The annual report provides useful additional transparency around the first full year of pEPR and the movement of producer funding through the system.
“It also reinforces the importance of robust producer data, stable fee modelling and clear visibility over how the money collected is being used. Producers need confidence not only in the accuracy and predictability of their liabilities, but that those costs translate into measurable improvements in collection and recycling.
“The FPA meets PackUK monthly and will continue to use those discussions to raise members’ concerns and seek greater transparency around data, costs, performance and outcomes as the scheme develops”.
PRN market remains under pressure as industry awaits clarity on possible intervention
High plastics Packaging Recycling Note prices continue to support recycled-material values and put upward pressure on prices across a number of plastic grades, according to the latest letsrecycle.com market report.
The report says the plastics market remained broadly stable during September but that high PRN prices were providing significant price support, including for PET where underlying demand remained subdued.
It adds that the sector is waiting to see whether Defra or the Environment Agency will intervene following pressure from producers over high compliance costs. Defra confirmed earlier in September that it was considering mitigation measures amid record PRN prices, although the precise form of any action has yet to be confirmed.
FPA comment:“The continuing uncertainty around PRNs is another reminder of the cumulative and sometimes unpredictable costs now facing packaging producers.
“Businesses need timely clarity over any intervention and, more broadly, greater stability and visibility across the different elements of packaging compliance. With pEPR costs now sitting alongside existing PRN obligations, predictability matters increasingly when companies are budgeting, pricing and making investment decisions”.
Large producers face 1 October pEPR reporting deadline
Large packaging producers were required to submit their latest packaging data by Thursday 01 October, covering packaging supplied or imported between 01 January and 30 June 2026.
Large producers are required to report packaging data every six months under pEPR. The same date is also the annual deadline for large producers to register for EPR and pay the applicable registration fees.
Government guidance advises any producer that has missed the reporting deadline to contact its relevant environmental regulator. The next reporting deadline for large producers will be 01 April 2027, covering the second half of 2026.
DRS registration opens as transition arrangements and recycling network take shape
Phase 1 registration requires businesses to provide core company, contact and address information, with further role-specific information to follow when Phase 2 opens in January 2027. Retailers in urban areas with less than 100m² of retail space are automatically exempt from operating a return point and do not need to register unless they choose to provide one. Other retailers seeking an exemption will still need to complete the registration process.
Importantly, PET and metal drinks containers filled before the launch date in England, Scotland and Northern Ireland will remain outside the scope of DRS and can continue to be sold afterwards. They will not require a DRS logo or registered barcode and will not attract a deposit or producer fee. Exchange for Change is encouraging businesses to sell through this stock by April 2028, although this will not be a regulatory requirement. Arrangements for Wales will be confirmed separately.
For unfilled packaging associated with orders placed before 01 October 2027, Exchange for Change is discussing possible transitional flexibility with regulators which could allow it to be filled and sold after launch. However, this has not yet been agreed. Non-DRS-compliant packaging that is not linked to a pre-launch order will not be able to be filled and placed on the market after the scheme starts unless it is updated to meet the requirements, including the DRS logo and registered barcode.
The update comes as Exchange for Change also builds the infrastructure needed to operate the scheme. Five waste-management and recycling providers have been appointed to collect and process returned containers – also processing the material specifically so i can be recycled back into new drinks containers. Six processing facilities or dedicated lines are expected to be operational for launch and around 400 collection vehicles are planned. The organisation estimates the network will support around 700 jobs.
Separate guidance for hospitality businesses confirms they will not generally be required to operate return points unless they are grocery retailers, although obligations will vary according to how in-scope drinks are sold and whether they are consumed on or away from the premises.
Useful links:
Exchange for Change – registration opens
Exchange for Change – transition arrangements
Exchange for Change – new UK recycling infrastructure
UKHospitality – DRS overview
FPA comment: “These transition arrangements provide some welcome practical clarity for businesses planning packaging, production and stock well ahead of the October 2027 launch.
“The distinction between filled stock already produced, packaging committed against existing orders and new packaging placed on the market after launch will be particularly important for manufacturers, distributors and their customers.
“There is still detail to resolve, including the proposed flexibility around unfilled packaging and the separate arrangements for Wales”.
IN BRIEF
Digital Waste Tracking becomes mandatory for receiving sites
Mandatory Digital Waste Tracking began in England and Wales on 01 October, requiring businesses that receive controlled waste to report relevant movements through the new digital service.
Records must normally be submitted within two working days of the waste being received. The requirement will extend to receiving sites in Scotland and Northern Ireland from January 2027, with later phases bringing waste carriers, brokers and dealers into the mandatory system.
Food manufacturers urged to review contracts as RAM costs move through supply chains
Food businesses are being urged to examine supply agreements as pEPR and RAM raise questions over where packaging costs ultimately fall.
Writing for Food Manufacture, barrister Bill Cordingley notes that the business legally liable for an EPR fee may not necessarily be the organisation that ultimately bears its economic cost, with costs potentially absorbed, negotiated with suppliers or passed through to customers.
He recommends businesses review supplier and customer contracts to establish responsibility for packaging data and the allocation of EPR-related costs. The analysis also warns that a red RAM rating does not necessarily mean packaging is physically unrecyclable, as missing information can itself result in a red assessment.
ELSEWHERE ...
Trial demonstrates potential food-grade recycling route for flexible PP
Trials have demonstrated a potential route for incorporating post-consumer food-grade recycled polypropylene into biaxially oriented polypropylene film used extensively in flexible food packaging.
Work involving the NEXTLOOPP project, Süper Film and Brückner Maschinenbau successfully processed recycled PP into BOPP film following laboratory testing and pilot-scale production trials. Packaging Europe reports that the material was processed without film breaks or significant disruption to the production process.
The initial work used recycled PP derived from a tightly controlled stream of previously used food packaging and tested formulations containing different proportions of recycled material, with a 20% recycled-content formulation identified as an initial commercially credible target.
The development is significant because BOPP films are widely used for products including snacks and other food packaging, but flexible PP has lacked an established closed-loop route capable of returning post-consumer material to food-contact film.
Further work will now be needed to demonstrate performance at full commercial production speeds and determine how readily the approach can be scaled.
North Somerset flexibles rollout highlights both collection potential and infrastructure challenge
North Somerset Council has collected more than 197 tonnes of soft plastics since introducing district-wide kerbside collections in June 2025, with resident participation exceeding expectations.
The council collects plastic bags and flexible plastic wrapping alongside its weekly household recycling service. More recent performance data covering the period to the end of March 2026 shows kerbside residual waste falling by 14%, while kerbside recycling increased by more than 6%.
However, the experience has also highlighted challenges further along the collection chain. North Somerset said it had underestimated the implications of handling flexibles once they reached the depot, particularly the time and cost involved in compacting and securely baling the material with unsuitable equipment.
The authority has since adapted its infrastructure and processes and has advised other councils considering flexible-plastics collections to examine baling requirements carefully before rollout.
FPA comment: “This is useful real-world evidence that household flexible-plastics collections can achieve strong participation, but it also underlines that successful collection is only one part of the equation.
“Appropriate sorting and handling infrastructure, sufficient reprocessing capacity and sustainable end markets all have to develop alongside collection systems. Those practical lessons should help inform the wider rollout of flexible-plastics collections and decisions over how producer funding is used to improve recycling outcomes”.
Co-op expands coffee pod recycling following successful trial
Co-op and Podback are expanding in-store coffee pod recycling to more than 200 stores following a six-month trial across 30 locations.
Consumers returned around eight tonnes of aluminium and plastic coffee pods during the trial – equivalent to more than 500,000 used pods.
Under the scheme, customers use Podback recycling bags before taking used pods to participating stores. The pods are then sent to UK processors for recycling, while recovered coffee grounds are used for applications including renewable biogas and agricultural soil improver.
The expansion provides another example of retailers using dedicated collection systems for packaging formats that are difficult to capture through conventional household recycling.
Commercial-scale production puts paper bottles to the test
British packaging company Pulpex is preparing to produce paper bottles at commercial scale from a new factory near Glasgow, with targeted annual capacity of around 40 million bottles.
The fibre-based containers are manufactured from moulded wood pulp and use a non-plastic, water-based barrier intended to enable liquids to be stored without the plastic liners traditionally used in some paper bottle concepts.
The Times reports that products using the technology are expected to reach consumers this autumn, with brands including Smol and Purely Scottish mineral water among the initial users. Pulpex says the bottles can be recycled through the paper waste stream.
The move will provide an important commercial-scale test of a packaging concept that has been under development for several years, including how the format performs through filling, distribution, consumer use and existing recycling systems.
Packaging taxes cited among continuing retail cost pressures
Packaging taxes are among the costs continuing to put pressure on UK retailers despite a slight easing in shop-price inflation, according to the British Retail Consortium.
BRC figures reported by Reuters showed annual shop-price inflation easing to 1.4% in September, while food inflation slowed to 2.5%.
BRC chief executive Helen Dickinson nevertheless said retailers were continuing to absorb higher costs, citing energy, employment, business rates and packaging taxes among the pressures affecting the sector.
The comments provide further evidence that packaging-related costs are increasingly being considered alongside wider operating and supply-chain pressures across the businesses ultimately buying and selling packaged goods.
EUROPE
EU green claims rules begin applying across member states
New EU rules aimed at tackling misleading environmental claims began applying across member states on 27 September 2026, adding another compliance consideration for businesses making sustainability claims about products and packaging sold into European markets.
The Empowering Consumers for the Green Transition Directive (ECGT), often referred to as the EU’s 'greenwashing' rules or EmpCo Directive, strengthens existing consumer-protection requirements around environmental claims and sustainability labels.
The rules restrict vague or generic environmental claims unless they can be supported by recognised evidence and require businesses to ensure that environmental information provided to consumers is clear, accurate and verifiable.
Although the Directive is not a packaging regulation in itself, it is highly relevant to foodservice packaging businesses because claims made on packaging and associated marketing materials – including statements about recyclability, compostability, recycled content or environmental performance – may fall within scope.
For UK businesses supplying packaged products into EU markets, the change reinforces the need to review environmental claims, supporting evidence and labelling practices alongside wider regulatory developments such as the Packaging and Packaging Waste Regulation (PPWR).
Businesses should also be aware that existing packaging stocks and transitional arrangements may need careful consideration where products carry environmental claims that no longer meet the updated requirements.
EU seeks targeted solution to PPWR EPR burden on smaller producers
EU member states have agreed that a targeted solution should be explored to address the potentially disproportionate burden that extended producer responsibility requirements under the Packaging and Packaging Waste Regulation could place on smaller packaging producers.
The issue was considered as part of the EU’s wider environmental simplification programme. Following discussions on 30 September, member states agreed that further work should explore a targeted solution for PPWR EPR obligations because of the possible disproportionate burden on small packaging producers.
Earlier proposals would have temporarily suspended rules requiring businesses to appoint an authorised representative for EPR when placing packaging on the market in another member state. However, negotiations on those proposals were discontinued in June after a large majority of member states raised reservations.
No change to the existing PPWR obligations has yet been adopted, and further legislative work will therefore be required.
For UK businesses supplying packaged goods into EU markets, the outcome will be important in determining whether future registration and authorised-representative requirements are simplified, particularly for companies trading across several member states.
Useful link: Read the Council update
INTERNATIONAL
New global standard targets food loss and waste
A new international standard has been launched to help businesses across the food supply chain prevent, measure and reduce food loss and waste.
BS ISO 20001 sets out a management-system framework that can be used by organisations including food manufacturers, distributors, retailers and foodservice operators to identify waste hotspots, introduce controls, monitor progress and report improvements.
US packaging EPR laws face further court challenges
Legal challenges to state packaging EPR programmes are continuing in the United States, with developments in both Oregon and Colorado.
The cases are being closely watched as packaging EPR expands across a growing number of US states and questions around producer obligations, fee-setting and responsibility continue to be tested through both regulation and the courts.
US senators seek federal ban on intentionally added PFAS in food packaging
Bipartisan legislation has been reintroduced in the US Senate that would prohibit intentionally added PFAS in food packaging at federal level.
The Keep Food Containers Safe from PFAS Act, introduced by Senators Maggie Hassan and Tommy Tuberville, would amend the Federal Food, Drug and Cosmetic Act to prohibit food packaging containing intentionally added PFAS from interstate commerce from 1 January 2028.
A corresponding bill was introduced in the House of Representatives earlier this year. More than a dozen US states have already introduced restrictions on PFAS in packaging, but there is currently no equivalent federal prohibition.
The development comes as regulators internationally continue to examine the treatment of PFAS in food-contact packaging and the evidence required to demonstrate compliance.
OTHER NEWS
UK
Packaging News: Paper packaging market projected to reach £400bn by 2033 as demand is supported by e-commerce, food delivery and moves away from plastic. Read more here.
The Grocer – partner feature: Five ways to future-proof packaging for a changing regulatory landscape, including EPR, PPWR, recyclability and the importance of planning packaging changes ahead of regulatory deadlines. Read more here
RECYCLING magazine: Britain’s plastics recycling sector faces a growing capacity gap as difficult market conditions continue to put pressure on domestic recycling infrastructure. Read more here
UKHospitality: New analysis finds hospitality has the highest effective business-tax burden among 11 major UK sectors, paying the equivalent of 82p in tax for every £1 of pre-tax profit. Read more here
RESEARCH AND TECHNOLOGY
Packaging Dive: Association of Plastic Recyclers launches a tool assessing the recyclability of the complete package – including resin, colour, adhesives, inks, barriers, closures and labels – with additional functionality for estimating EPR fees in parts of the US and Canada. Read more here
New Food Magazine: Researchers develop biodegradable starch-based sensor that changes from blue to pink when moisture enters food packaging, potentially providing a simple visual indicator of freshness and pack integrity. Read more here
EUROPE
Packaging Europe: More than 40 industry associations call for the forthcoming EU Circular Economy Act to strengthen and further harmonise extended producer responsibility frameworks. Read more here
Packaging Europe: Plastics recycling should be treated as strategic European infrastructure, argues new analysis examining the investment needed to meet PPWR recycled-content requirements. Read more here
Packaging Europe: With PPWR now applying, industry analysis examines how far businesses have progressed with implementation and where significant compliance questions remain. Read more here
INTERNATIONAL
Packaging Dive: US Flexible Film Initiative announces its first recycling contracts after moving more than three million pounds of flexible plastic packaging from California collection programmes to North American reclaimers. Read more here
Packaging Dive: Growth in private-label products creates new opportunities for packaging manufacturers and designers as retailers increasingly develop distinctive identities for their own-brand ranges. Read more here
FPA NEWS & EVENTS
FPA in the news
Packaging Brains: FPA seeks clarity on threshold and evidence requirements for PFAS
Packaging News: FPA seeks clarity on threshold and evidence requirements for PFAS
Packaging News: Welsh flexibles trial highlights recycling potential and collection challenge
Louisa Goodfellow appointed chair of FPA SAGA Committee
Louisa Goodfellow of Ecosurety has been appointed chair of the FPA’s Sustainability & Government Affairs (SAGA) Committee, following the retirement of Adrian Pratt of Benders Cups.
Louisa is already an active member of the committee and, as Policy Manager at Ecosurety, brings extensive knowledge of environmental policy, producer responsibility and the rapidly evolving regulatory landscape affecting FPA members.
Her appointment comes at a particularly important time, with the sector continuing to navigate major changes including packaging EPR, RAM, the EU Packaging and Packaging Waste Regulation (PPWR), Plastic Packaging Tax and Deposit Return Schemes.
Under Louisa’s leadership, the SAGA Committee will continue to monitor emerging legislation and regulation, help shape FPA policy and representations to government, and translate complex developments into practical information and guidance for members.
We look forward to working with Louisa as she leads the committee into its next chapter.
Talking Rubbish recording live at the 2026 FPA Environment Seminar
Taking place on Thursday November 05 at Stationers' Hall, City of London, this year’s programme brings together policy-makers, regulators, sustainability experts and industry leaders to examine the issues shaping the future of foodservice packaging – from EPR and the changing regulatory landscape to sustainable design, AI, life cycle analysis, consumer confidence and compliance.
Robbie Staniforth and James Piper from Talking Rubbish will be recording live at the event, where sessions will explore what the first year of EPR has taught us and what comes next; how industry, government and regulators can work together to build better regulation; how manufacturers can respond to evolving UK and European legislation; and how emerging technologies can support better environmental decision-making.
The programme also looks further ahead, with the next generation’s perspective on sustainable packaging and product design, alongside practical discussion of how businesses and regulators can strengthen compliance and enforcement.
Speakers and contributors currently include representatives from PackUK, Ecosurety, SUEZ, the National Physical Laboratory, Carbon Trust, Greyparrot, the LCA Centre, the Vegetarian Society, CMA, the Packaging Federation and INCPEN, with further announcements to follow.
Confidential input requested
Businesses with concerns about how pEPR is operating in practice – including issues relating to scope, competition, enforcement or unintended consequences, are invited to share their experiences in confidence with the FPA. We also welcome intelligence on potential gaps in scope, market distortions or suspected avoidance behaviours, which can be shared in confidence.
This insight is invaluable in ensuring industry concerns are effectively represented in our ongoing engagement with Defra, PackUK and the Environment Agency.
Please contact the compliance team directly via compliance@foodservicepackaging.org.uk. All information will be handled sensitively and used to inform our evidence base and policy discussions.
EXTERNAL EVENTS & PARTNER NEWS
Defra Circular Economy stakeholder forum dates
Defra's Circular Economy Joint Stakeholder Forums provide businesses and other stakeholders with regular updates on packaging, waste and wider circular economy reforms.
Stakeholders will hear updates from Defra's Circular Economy Directorate, PackUK, the Environment Agency and other relevant bodies, learn about policy and operational developments, and have an opportunity to put questions to officials.
The link is different each month, so it is important to use the correct link for each session. Microsoft Teams will then send a calendar invite automatically for the date you have registered.
Upcoming forums:
Tuesday 06 October
2:30 PM – 4:00 PM
Register for 06 October session
Tuesday 03 November
2:30 PM – 4:00 PM
Register for 03 November session
Tuesday 01 December
2:30 PM – 4:00 PM
Register for 01 December session
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