The FPA Friday Digest

Yesterday's FPA Environment Seminar brought together government, regulators, industry representatives and technical experts for a day of discussion about the opportunities and challenges facing foodservice packaging.

Closing the event, FPA interim executive chair Paul Synnott reflected on the breadth of perspectives presented, the assumptions challenged and the importance of turning complex issues into practical solutions. Despite the many challenges facing the sector, he reminded delegates of its resilience and ability to adapt, innovate and work together, while emphasising the importance of recognising the contribution foodservice packaging makes to food security, convenience and everyday life.

A recurring theme throughout the day was the need for greater policy certainty to support long-term investment. Paul also highlighted the importance of taking consumers with us through better information and education, recognising that UK businesses operate within a wider European market, and approaching emerging technologies such as artificial intelligence with both enthusiasm and appropriate caution.

With discussions ranging from recycling behaviour and environmental claims to labelling, AI and the future of packaging EPR, Paul reaffirmed the FPA's commitment to representing members' views, challenging where necessary and working constructively with government to ensure practical industry experience remains central to policy development.

He also echoed UK Packaging PRO chair Sebastian Munden's invitation for obligated producers to become PRO members, encouraging businesses to ensure their voices are heard as the scheme develops.

We will publish a special Environment Seminar edition of the Friday Digest next week, bringing together fuller reports from the presentations and panel discussions, together with the key messages and conclusions emerging from the day.

Meanwhile, this week's Digest examines further parliamentary scrutiny of the cumulative impact of packaging regulation, PackUK's new approach to developing the Recyclability Assessment Methodology and UK Packaging PRO's plans to strengthen industry engagement.

We also look at government's evaluation of Plastic Packaging Tax, developments affecting producer compliance and enforcement, and the implications of the European Commission's decision to withdraw its proposed Green Claims Directive. Elsewhere, we report on Germany's proposed plastics packaging tax and other developments from across the UK and international packaging sector.

Our thanks once again to all our speakers and panellists for sharing their expertise so openly, to everyone who contributed to the discussions – to Packaging Innovations and Empack for sponsoring the event and to GoPak for sponsoring the refreshments.

PackUK reveals one in seven producers supplies exclusively red-rated packaging

Almost 20% of household packaging placed on the UK market is classified as red under the Recyclability Assessment Methodology (RAM), while approximately one in seven producers supplies exclusively red-rated packaging, according to figures presented by PackUK at the FPA Environment Seminar on 5 November.

PackUK chief executive Jeremy Blake told delegates that the first round of RAM assessments highlighted the scale of the challenge in moving towards a more circular packaging system. Figures accompanying his presentation showed that 14% of producers supplied exclusively red-rated packaging, 75% supplied packaging with mixed recyclability ratings and 10% supplied only green-rated packaging.

Blake suggested that eliminating or improving packaging incompatible with existing recycling systems could help the UK achieve recycling rates in the region of 80–85% over time. However, this was presented as a potential outcome rather than a formal forecast.

Looking ahead, Blake revealed that PackUK expects to launch a call for evidence in early 2027 on additional factors that could influence future pEPR fee modulation. Recycled content and overpackaging were identified as possible areas for consideration, although no decisions have been taken.

He also sought to reassure producers that the pace of changes to RAM would slow considerably. RAM 2028 is expected to remain broadly consistent with RAM 2027, with amendments requiring a clear business case and supporting technical evidence.

PackUK is working with UK Packaging PRO on a more transparent process for considering industry proposals, including reviews of existing guidance on PFAS and direct printing on polypropylene.

Blake also confirmed plans to publish local authority effectiveness assessments from 2028, providing greater visibility of how producer funding is contributing to improvements in collection and recycling services.

The FPA will provide fuller coverage of Blake's presentation and the wider discussions at the Environment Seminar in a special edition of the Friday Digest next week.

FPA comment: “The indication that almost 20% of household packaging is red-rated, and that one in seven producers supplies exclusively red-rated packaging, highlights the scale of the challenge facing the industry. However, it also underlines the importance of understanding why materials receive those classifications and what practical opportunities exist to improve their recyclability.

“The FPA welcomes PackUK's commitment to greater stability in RAM and a more transparent, evidence-led approach to future changes. Producers need clear, consistent requirements that allow them to make informed decisions about packaging design and investment.

“Any proposals to extend fee modulation to recycled content, overpackaging or other factors must also be carefully assessed against existing regulations, including Plastic Packaging Tax, to avoid overlapping requirements or unintended consequences.

“Ultimately, the success of pEPR must be measured not just by changes in packaging classifications, but by demonstrable improvements in collection, sorting, reprocessing and the availability of viable end markets. Greater transparency over local authority performance and the outcomes achieved through producer funding will be essential”.

UK Packaging PRO invites producers to register interest in membership programme

UK Packaging PRO is encouraging obligated producers to register their interest in its developing membership programme as it strengthens industry representation within packaging extended producer responsibility (pEPR).

Speaking during a panel discussion at the FPA Environment Seminar yesterday, PRO chair Sebastian Munden CBE emphasised that government is focused on implementing existing legislation rather than undertaking a fundamental review of the scheme. The PRO intends to work within that framework, bringing together evidence and practical experience from trade associations and producers to develop constructive recommendations for improving implementation. Dedicated trade association briefings are also being organised to support this work.

Closing the Seminar, FPA interim executive chair Paul Synnott encouraged obligated producers to become involved to ensure their voices are heard. Further information is available through the UK Packaging PRO website

PackUK sets out new approach to RAM development as producers prepare for Year 2 fees

PackUK has outlined a new process for developing future versions of the Recyclability Assessment Methodology (RAM), with greater emphasis on technical evidence, producer engagement and transparency over proposed changes.

Speaking at the Circular Economy Joint Stakeholder Forum on 03 November, PackUK said future revisions would focus on a smaller number of targeted priorities rather than significant annual redesigns of the methodology.

Under the new process, stakeholders will be invited to submit proposals for changes to RAM, supported by technical evidence, by 31 December 2026. The UK Packaging PRO will then review and prioritise submissions, developing recommendations through technical assessment and stakeholder engagement.

Proposals will subsequently be considered by a RAM Decision Board before receiving final approval from PackUK and the four UK administrations. RAM 2028 is scheduled for publication in summer 2027.

PackUK said the process is intended to bring producer insight and expertise closer to decisions about how RAM develops, with greater visibility over which changes are being considered and why.

PackUK confirmed it is already working with the PRO to review existing guidance on PFAS and direct printing on polypropylene packaging in response to producer feedback.

The announcement comes amid continuing industry concerns about the treatment of PFAS under RAM 2027, including the potential for otherwise recyclable packaging to receive an adverse classification.

PackUK also presented a provisional annual calendar for the scheme, confirming that Year 2 Notices of Liability and producer fees are expected to be issued during November 2026.

The calendar provides greater visibility over future reporting requirements, fee notifications, local authority payments and the introduction of subsequent RAM versions.

FPA comment: “We welcome PackUK's commitment to a more transparent, evidence-led approach to developing RAM and the opportunity for producers to contribute technical expertise before decisions are made.

“The proposed process is a positive step, particularly if it results in more targeted changes, clearer explanations of the evidence underpinning them and greater certainty for businesses making packaging and investment decisions.

“The confirmation that PackUK and the UK Packaging PRO are reviewing guidance on PFAS and direct printing on polypropylene in response to producer feedback is encouraging. However, significant concerns remain about the proposed approach to PFAS classification. It is essential that requirements are scientifically justified, proportionate and technically achievable, particularly for food-contact packaging, and that industry receives clarity on whether changes can be made before RAM 2027 takes effect.

“The FPA has established monthly meetings with PackUK and will continue to use that engagement to represent members' concerns and contribute practical evidence. The priority must be to ensure that RAM supports genuine improvements in recyclability while avoiding unnecessary costs, unintended environmental consequences or uncertainty for businesses investing in packaging innovation”.

MPs question cumulative impact of packaging regulation as government confirms EPR review timetable

A series of parliamentary questions has highlighted growing concerns about the cumulative cost and administrative burden of packaging regulation, with Defra confirming that a formal post-implementation review of packaging Extended Producer Responsibility (pEPR) will not be completed until the end of 2028.

Labour MP Chris Bloore asked Environment Minister Emma Hardy about the impact of packaging EPR costs and regulatory uncertainty on industrial growth, manufacturing investment and competitiveness, as well as the potential for a cross-government review involving HM Treasury, the Department for Business and MHCLG.

In response, the Government confirmed that Defra regularly engages with HM Treasury and MHCLG on pEPR and that a post-implementation review will take place by 31 December 2028, followed by a wider evaluation of the Collection and Packaging Reforms in 2029.

Other questions addressed the cumulative administrative costs of EPR, the interaction with the Packaging Recovery Note (PRN) system and Plastic Packaging Tax, the potential for avoidance through existing reporting thresholds, and the effect of Recyclability Assessment Methodology (RAM) fee modulation on manufacturing and recycling investment.

On PackUK's performance, the Government confirmed that the Government Internal Audit Agency has reviewed its financial processes and is undertaking further work covering operational controls, strategy, key performance indicators and assurance arrangements.

Meanwhile, an Early Day Motion sponsored by Liberal Democrat MP Sarah Olney has highlighted concerns that businesses failing to meet their packaging obligations are gaining an unfair advantage over compliant producers, particularly amid the shortage of PRNs.

The parliamentary activity reinforces continuing industry calls for greater transparency, effective enforcement and a proportionate approach to packaging regulation.

The questions echo concerns raised by the FPA's Companies House investigation earlier this year, which identified potential gaps in the visibility of packaging businesses within the producer registration system and raised questions about the risk of costs being shifted onto compliant producers.

FPA comment: “The parliamentary questions highlight issues businesses across the packaging supply chain have been raising for some time: the cumulative cost of regulation, the impact on investment and competitiveness, and whether the systems being introduced are delivering the intended outcomes.

“While government's commitment to a formal review of packaging EPR by the end of 2028 is noted, businesses cannot afford to wait until 2029 for meaningful scrutiny of a scheme that is already having significant financial and operational implications. There must be mechanisms for identifying and addressing problems as they emerge.

“Equally important is ensuring that businesses meeting their regulatory obligations are not placed at a competitive disadvantage by those that do not. At this week's Circular Economy Joint Stakeholder Forum, the Environment Agency reported that it had investigated thousands of suspected free riders. While this is encouraging, the figures also include businesses subsequently found not to be obligated, making it difficult to establish the scale of genuine non-compliance or the effectiveness of enforcement.

“The FPA will be seeking further clarification from PackUK and the Environment Agency on the number of businesses found to be non-compliant, the additional packaging tonnage and financial obligations identified, and the outcomes of enforcement activity. We also want to establish whether non-compliance is resulting in additional costs being borne by businesses meeting their obligations.

“Ultimately, regulation must be proportionate, evidence-led and deliver measurable environmental benefits. Businesses need confidence that the substantial costs they are being asked to bear are translating into improvements in collection, recycling and domestic reprocessing capacity, rather than simply adding to the administrative burden. The FPA will continue to press for greater transparency, effective enforcement and a regulatory framework that supports investment in UK manufacturing and recycling”.

Metal packaging industry warns conflicting policies threaten UK manufacturing

The Metal Packaging Manufacturers Association (MPMA) has warned that conflicting environmental, trade and industrial policies are undermining the competitiveness of UK metal packaging manufacturers and could encourage production to move overseas.

Launching a new manifesto on 04 November, the association called for greater coordination between packaging EPR, Deposit Return Schemes, steel tariffs, energy policy and the Carbon Border Adjustment Mechanism (CBAM).

The MPMA argues that current pEPR fees can make steel food cans more expensive than competing packaging formats, potentially encouraging material substitution without sufficient consideration of the wider environmental, economic and food-security implications.

The manifesto adds to growing industry calls for government to assess the cumulative impact of packaging regulation rather than considering individual measures in isolation.

FPA comment: “The MPMA's concerns echo those the FPA has been raising about the cumulative impact of packaging regulation on UK manufacturers and the risk of unintended consequences when policies are developed in isolation.

“Decisions about packaging materials cannot be based on regulatory cost alone. Food safety, product protection, resource efficiency, recyclability and the availability of domestic recycling infrastructure all need to be considered.

“The FPA supports the principle that packaging producers should contribute to the cost of managing packaging waste, but the system must be fair, proportionate and based on sound evidence. It should not inadvertently discourage investment in UK manufacturing or encourage material substitution without demonstrable environmental benefits.

“Government's industrial strategy and environmental objectives must work together. That requires regular assessment of the combined financial and operational burden on businesses, alongside transparent evidence that the policies are delivering the intended outcomes”.

Government confirms EU sachet restrictions will not apply in the UK

Government has confirmed that proposed EU restrictions on single-serving sachets and containers will apply in Northern Ireland under the Windsor Framework, but will not extend to the rest of the UK through the EU-UK reset.

Responding to a parliamentary question from Conservative MP Mike Wood, Environment Minister Emma Hardy said government was planning a consultation on potential UK alignment with the EU's approach.

The restrictions concern single-serving packaging used for products including ketchup, mayonnaise, sugar, salt, oil and vinegar, with potential implications for foodservice operators and manufacturers supplying portion-control packaging.

The distinction between Northern Ireland and Great Britain is particularly relevant to businesses supplying across the UK, which could face different regulatory requirements depending on the destination market.

Government's planned consultation should provide an opportunity for industry to highlight the practical implications of any proposed alignment, including food hygiene, portion control, accessibility and the availability of alternative packaging formats.

Read the parliamentary question

Scotland consults on new recycling code, including flexible plastics

The Scottish Government has launched a consultation on a new statutory Household Recycling Code of Practice intended to make recycling services more consistent and improve the quantity and quality of materials collected across the country.

The proposals include a common set of core recyclable materials, more consistent separation of paper and card from plastic, metal and cartons, limits on residual waste capacity and improved arrangements for food waste collections.

Of particular interest to the packaging industry, the draft Code clarifies that local authorities should collect flexible plastic packaging and films as part of their household recycling services. The proposed definition covers polyolefin films and bags containing at least 90% by weight of mono-polyethylene, mono-polypropylene or both, including carrier bags, bread bags, produce bags and wrapping films.

The Scottish Government estimates that flexible plastics account for more than 27% of consumer plastic packaging but have achieved a UK-wide collection and recycling rate of around 7% in recent years.

The proposed Code also recommends a minimum twin-stream approach to dry recycling, separating fibres from containers, with the intention of reducing contamination and improving material quality.

The consultation closes on 21 January 2027. The final Code will be developed following consideration of responses and a further stage of consultation.

FPA Comment: "Greater consistency in household recycling collections is welcome, but changes to collection requirements must be matched by investment in sorting and reprocessing capacity.

"The challenge for foodservice packaging is not just whether a material can be collected but whether it can be recovered and recycled effectively in practice.

“The FPA would encourage the Scottish Government to consider the entire recycling system, including contamination, material quality, infrastructure and viable end markets, when developing its new Code of Practice”.

Environment Agency reports progress tackling suspected pEPR freeriders

The Environment Agency says it has investigated and brought into compliance thousands of suspected freeriders under pEPR, although the figure includes businesses subsequently confirmed as not obligated.

Speaking at the Circular Economy Joint Stakeholder Forum, the Agency said it was expanding its compliance monitoring activities, including packaging data checks, on-site audits and intelligence-led investigations.

Specialist teams have been established covering waste fraud and error, compliance monitoring and civil sanctions, with enforcement action considered where necessary.

The update follows growing industry and parliamentary concerns about businesses avoiding their packaging obligations and the resulting impact on compliant producers.

New Plastic Film Forum launched ahead of 2030 collections

Defra has launched a Plastic Film Forum to support the introduction of mandatory household and workplace collections of plastic film packaging in England from April 2030.

The Forum held its first meeting on 02 November, bringing together representatives from local authorities, waste collectors, producers, retailers, reprocessors and government departments.

Its work will focus on addressing the challenges that have contributed to the proposed delay from March 2027, including high collection costs, insufficient sorting and reprocessing infrastructure, and limited market demand for the material. The Forum is expected to meet again in December, with specialist working groups examining collection, sorting, reprocessing and end markets due to launch in January 2027.

Government says it remains committed to increasing plastic film recycling and achieving its longer-term ambition of a 65% municipal recycling rate by 2035.

PackUK outlines changes to local authority
payment calculations

PackUK has identified five areas of change for Year 3 of packaging extended producer responsibility (pEPR), including updated data sources, the collection of new materials such as flexible plastics, changes to local authority groupings, the Deposit Return Scheme and recycling target adjustments in Wales.

The changes were outlined at the Circular Economy Joint Stakeholder Forum on 03 November, alongside a reminder that payments to local authorities are now distributed quarterly.

PackUK said it aims to issue local authority Notices of Assessment by November each year.

PackUK clarifies disposal-fee calculations and appeals process

Updated government guidance explains how packaging EPR disposal fees are calculated, including adjustments based on RAM recyclability ratings, and the procedures available to producers who believe their Notices of Liability are incorrect. Businesses must first contact the PackUK helpdesk and follow its formal complaints procedure before appealing a disputed fee to the appropriate tribunal. The guidance also sets out the penalties that may apply for non-payment. Members expecting Year 2 Notices of Liability this month are encouraged to familiarise themselves with the arrangements. Read more here

Defra clarifies reporting arrangements under DWT

Defra has provided further guidance on reporting under the Digital Waste Tracking service, one month after mandatory reporting began for permitted or licensed waste receiving sites in England and Wales.

Organisations can submit records through compatible software connected to the service's application programming interface (API), or by spreadsheet upload. The spreadsheet option is intended as a temporary route and will remain available until at least October 2027.

Defra also confirmed contingency arrangements for service outages, requiring operators to maintain records and submit outstanding information once the system is restored.

Mandatory reporting for receiving sites in Scotland and Northern Ireland is scheduled to begin in January 2027.

First 54 reverse vending machines approved for UK DRS

Exchange for Change has published its first list of certified reverse vending machines ahead of the planned October 2027 launch of the UK Deposit Return Scheme.

The list includes 54 models from seven manufacturers, with further machines expected to be added as they complete testing. Each model has been assessed against 77 requirements covering container recognition, fraud prevention, scheme connectivity, data handling and accessibility.

Small independent retailers installing machines can also apply for grants of £6,000 per site from the scheme's £60m support fund.

Import tariff suspensions – applications open 11 November

Following the Autumn Budget, businesses will have an opportunity to request additional import tariff suspensions covering qualifying goods.

Government is extending existing suspensions across sectors including chemicals, plastics, fibres, and food and drink. A new application window will run from 11 November 2026 to 03 February 2027.

Members importing specialist packaging materials, raw materials or manufacturing components may wish to review whether duty relief could be relevant to their operations.

Read the Budget announcement here

Government launches new crackdown on
organised waste crime

Environment Secretary Dame Angela Eagle has announced a new Waste Crime Crackdown Group bringing together ministers, police, regulators and local authorities to strengthen enforcement against organised waste crime.

Launched on 04 November, the group will identify weaknesses in the waste system exploited by criminals, improve intelligence-sharing and examine whether further enforcement powers are needed.

Defra says 36 arrests have been made since April as part of increased action against illegal waste activity, while the Environment Agency has been using additional investigative techniques and enforcement measures to target illegal operators.

The initiative follows growing concern about the scale and economic impact of waste crime, alongside questions about whether existing regulatory powers are being used effectively.

Although the crackdown focuses on illegal waste operations rather than packaging producer compliance specifically, it raises wider questions about enforcement effectiveness and the importance of ensuring that legitimate businesses are not disadvantaged by those operating outside the rules.

Read the government's announcement here

FPA comment: “The FPA welcomes stronger action against waste crime and greater cooperation between government, regulators and enforcement agencies. Businesses operating responsibly should not face unfair competition from those who disregard environmental requirements.

“However, announcing additional enforcement activity is only part of the answer. It is equally important to demonstrate that existing powers are being used effectively and that interventions are producing measurable results.

“The same principle applies to packaging EPR, where compliant producers need confidence that non-compliance is being identified and addressed, and that the financial burden of the scheme is being distributed fairly.

“We would welcome regular publication of meaningful enforcement data, including the number of confirmed breaches, the action taken and the outcomes achieved”.

Government refers MPs to 2024 assessment amid further questions over pEPR costs

Government has responded to six parliamentary questions from Gregory Stafford MP concerning the impact of packaging extended producer responsibility (pEPR) on prices, brewing and hospitality businesses, and the treatment of packaging disposed of through commercial rather than household waste streams.

Stafford also asked whether government would publish comparative international data on glass packaging fees and evidence concerning the scheme's implementation.

In identical responses issued on 04 November, Environment Minister Emma Hardy referred to government's October 2024 impact assessment, acknowledging that it considered packaging producers collectively rather than providing separate estimates for the brewing sector.

The responses did not provide the specific sectoral assessments or further information requested. The questions add to growing parliamentary scrutiny of pEPR's cumulative costs and their implications for businesses.

View the parliamentary questions and answers here

Nigeria introduces new recycled-content requirements and restrictions on plastic packaging

Nigeria has introduced a new national regulatory framework for plastic waste, combining mandatory recycled-content requirements, chemical restrictions and extended producer responsibility obligations.

Ghana warns of confiscation as polystyrene food packaging ban approaches

Ghana's Environmental Protection Authority has warned manufacturers, importers, retailers and food vendors that prohibited expanded polystyrene packaging could be confiscated and destroyed when the country's nationwide ban takes effect on 01 January 2027. The restrictions cover the production, importation, distribution, sale and use of polystyrene foam products, including takeaway food containers, cups and plates

UK

Packaging News: Nottingham City Council expands household recycling collections to include plastic bags, crisp packets and flexible packaging. Read more here

ESG Today: UK Government announces plans for mandatory human rights due diligence legislation covering large businesses and their supply chains. Read more here

Resource Media: UK circular economy jobs stall despite £93bn potential growth, according to WRAP. Read more here

Packaging Europe: Cano Water prepares to launch lightweight aluminium bottles in Waitrose and through foodservice wholesaler Brakes. Read more here

Resource Media: UK Health Security Agency announces plans to measure PFAS exposure levels in the population. Read more here

letsrecycle.com: Veolia opens new circular economy hub and reuse facilities in Birmingham. Read more here

RESEARCH AND TECHNOLOGY

Packaging News: Polytag expands its packaging tracking technology into Scotland with installation at Wyllie Recycling's materials recovery facility. Read more here

letsrecycle.com: Amcor research finds recyclability influences purchasing decisions for a third of coffee pod consumers. Read more here

IN Food: European BORN consortium advances research into heat-resistant bio-based food packaging. Read more here

letsrecycle.com: Enfield launches 1,000-home food waste recycling trial using caddies made from UK recycled plastic. Read more here

Packaging Europe: Billerud introduces lighter corrugated flute material designed to improve strength and reduce packaging weight. Read more here

EUROPE

Packaging Europe: European Commissioner clarifies that reusable packaging already in circulation will not need redesigning under forthcoming PPWR labelling requirements. Read more here

Packaging Europe: Industry examines practical challenges of implementing the Packaging and Packaging Waste Regulation. Read more here

Packaging journal: European producer responsibility organisations EXPRA and EPRO call for improvements to PPWR implementation, recycling rules and imported recyclate controls. Read more here

Packaging Europe: Nivea and ExxonMobil develop collation shrink film incorporating post-consumer recycled polyethylene. Read more here

INTERNATIONAL

Packaging Europe: Seven-Eleven Japan begins using biomass-derived thermal paper labels for takeaway food packaging. Read more here

Eco-plastics in Packaging: Operation Clean Sweep expands into India to help prevent plastic resin loss across the manufacturing supply chain. Read more here

NIA Ecology: Russia proposes new arrangements allowing importers to offset environmental fees on goods and packaging subsequently exported or used in further production. Read more here.

Packaging Europe: General Mills introduces resealable Ziploc bags for Cheerios cereals in the United States. Read more here

Eco-plastics in Packaging: Mold-Masters opens expanded manufacturing and engineering facility for plastics processing equipment in India. Read more here