The FPA Friday Digest

This week’s Digest comes against a backdrop of renewed debate over the future of pEPR, after the Conservative Party pledged to scrap the regime if elected.

While that proposal would require a future change of government and legislation, the current system continues to move forward. PackUK has set out its autumn programme, including Year 2 fees and Notices of Liability, its five-year strategy, further work with UK Packaging PRO on RAM 2028 and a forthcoming call for evidence on fee modulation. HMRC has also published the draft rules that will allow chemically recycled plastic to be accounted for through mass balance under Plastic Packaging Tax from April 2027.

There are further opportunities for industry to influence the direction of policy, with a new government survey seeking businesses’ experience of pEPR and the Environment Agency providing more detail on its work to identify and tackle free-riders.

Elsewhere, we report on a major new UK investment as Pulpex opens its first commercial fibre-bottle manufacturing facility in Glasgow, while in Europe more than 40 industry organisations are calling for greater harmonisation of EPR rules across the Single Market.

Our international round-up includes Japan’s new common recyclability testing protocol for flexible films and the latest plastics recycling figures from South Africa.

In FPA news, Henry Lee of Cromwell Polythene has been appointed to the FPA Board, and ticket sales are gathering pace for this year's FPA Environment Seminar.

Lastly, many congratulations to FPA members recognised at this week’s UK Packaging Awards, including Go-Pak, i2r Packaging Solutions and EP Group.

Conservatives pledge to scrap pEPR

The Conservative Party has pledged to abolish pEPR as part of a wider package of measures aimed at reducing regulatory costs for businesses.

The proposal, announced at the Conservative Party conference, would also see the Environment Agency and Natural England abolished as separate arm’s-length bodies, with their functions transferred into Defra.

The pledge was made by Shadow Chancellor Andrew Griffith who described the regime as an “administrative nightmare for business” and said a future Conservative government would scrap what he called the “packaging tax”. He said the measures were intended to cut regulation and support economic growth and argued it was adding to pressure on food prices.

The British Retail Consortium welcomed the proposal. Chief executive Helen Dickinson said packaging costs had risen sharply and argued that producers were now facing around £3bn a year in combined recycling-related charges, putting further pressure on prices and employment.

FPA comment: “The fact that such a fundamental change to pEPR is now being proposed demonstrates just how important it is for the current system to show businesses what their money is achieving.

“Whatever the political debate about the future shape of the system, constant change carries costs of its own. The immediate priority should remain making pEPR proportionate, transparent and evidence-led, with clear accountability for the considerable sums being collected from producers".

PackUK sets out autumn pEPR roadmap as UK Packaging PRO takes greater role

PackUK has set out the next phase of packaging EPR delivery, including Year 2 producer fees, publication of its five-year strategy, further development of RAM and a forthcoming call for evidence on the future of fee modulation.

Speaking at this week’s Circular Economy Joint Stakeholder Forum, PackUK said Year 2 fees and Notices of Liability are expected at the end of November, alongside publication of its five-year strategy.

It also confirmed that work with UK Packaging PRO will be scaled up, including development of RAM 2028 and public information campaigns, while a call for evidence on the future of modulation is also planned. Further work is continuing on the Efficiency & Effectiveness model used to assess local-authority waste management performance.

The update builds on PackUK's announcement at London Packaging Week that UK Packaging PRO is to take a greater role in the next iteration of the Recyclability Assessment Methodology, including responsibility for providing producer input into the development of RAM 2028.

PackUK’s wider roadmap describes 2026-28 as the period in which the scheme moves from establishing its foundations to 'mobilising delivery', before a further phase from 2028 focused on strengthening incentives, local-authority effectiveness assessments and continuing development of RAM with the producer-led organisation.

FPA comment: “Greater forward visibility is welcome, particularly around Year 2 fees, RAM 2028 and the future of modulation.

“The forthcoming call for evidence on modulation will be especially important. Producers need confidence that fee differentials are based on robust evidence, real-world recycling outcomes and requirements that can be demonstrated consistently in practice.

“We also welcome a stronger formal role for producers in the development of future versions of RAM. Businesses affected by the methodology need a meaningful opportunity to contribute evidence about how packaging performs in practice and about the feasibility of demonstrating compliance.

“Through our monthly meetings with PackUK, alongside our engagement with UK Packaging PRO, we will continue to ensure members’ experience is fed into the development of the scheme”.

HMRC publishes draft PPT mass balance rules

HMRC has published draft regulations setting out how chemically recycled plastic will be accounted for under the Plastic Packaging Tax (PPT) from April 2027.

The government has already confirmed that a mass balance approach will be introduced to allow chemically recycled plastic to count towards the tax's recycled-content requirements. The latest consultation sets out the detailed conditions businesses will need to meet.

These include requirements covering attribution methodology, certification, auditing, monitoring and record keeping. HMRC has also published a draft methodology for dealing with refinery and petrochemical outputs that can be used for both plastic and non-plastic applications.

The change is intended to allow chemically recycled material to qualify for the PPT where a direct physical link between recycled feedstock and an individual packaging item cannot be demonstrated.

The government has previously highlighted chemical recycling as potentially important for harder-to-recycle plastics, including films, and for applications such as food-contact packaging where suitable mechanically recycled material may be limited.

New guidance sets out PRN and PERN issuing requirements

Defra has published new guidance explaining how accredited reprocessors and exporters should issue Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs) under EPR.

The guidance sets out what packaging waste is eligible for evidence, the documentation businesses need to retain, when evidence can be issued and cancelled, and how income generated from PRNs and PERNs must be used and reported.

PRNs can only be issued by accredited reprocessors for eligible UK-derived packaging waste received at an accredited site, while PERNs can only be issued by accredited exporters once eligible material has been received by an approved overseas reprocessing site.

For 2026/27, evidence can be issued against the target material together with material 'reasonably associated' with it. Examples given include labels and lids attached to bottles, tape and staples on cardboard boxes and labels attached to plastic film.

The guidance also confirms PRN and PERN income must be spent in line with the business plan submitted during accreditation. Permitted uses include recycling infrastructure, price support, collection and transport costs, communications and developing markets or new uses for recycled packaging.

Accredited operators must report their income and how it was spent in an annual report due by 28 February following the accreditation year.

View the updated main pEPR collection page

Producers urged to contribute to government pEPR survey

Packaging producers are being encouraged to contribute to a new government survey examining the impact of circular-economy and packaging policies on businesses.

The Product and Packaging Producer Survey 2026 will open on 12 October and run until 20 November.

Ipsos is conducting the research on behalf of Defra in collaboration with the Welsh Government, Scottish Government and Northern Ireland’s Department of Agriculture, Environment and Rural Affairs.

The survey will examine businesses’ experience of circularity and sustainability, consumer trends, waste management and changes in the resource and waste policy landscape, including specifically how pEPR has affected business decision-making.

Responses will be confidential and anonymised, and the government says findings will help inform future packaging policy, implementation and governance.

Survey invitations will be distributed through regulators, Defra’s Circular Economy newsletter and directly by Ipsos to a sample of relevant businesses.

FPA comment: “We would encourage businesses receiving the survey to take part. If government is to understand the real impact of pEPR, it is important evidence comes directly from the businesses dealing with the cost, reporting and operational consequences of the scheme.

“We have consistently called for policy to be based on robust evidence, so this is an opportunity for producers to make sure their experience is reflected in that evidence base”.

CPI questions whether ‘recyclable’ is enough under RAM 2027

The Confederation of Paper Industries (CPI) has questioned whether the Recyclability Assessment Methodology for 2027 goes far enough in distinguishing between packaging that can technically be recycled and packaging that delivers good recycling outcomes in practice.

Writing for letsrecycle.com, CPI executive director Dimitra Rappou argues that fibre-based composite packaging containing laminates, coatings, metallisation, adhesives or other non-paper components can reduce fibre recovery, increase rejects and processing costs and affect the quality of recovered material.

CPI warns treating these formats in the same way as simpler paper and card packaging risks rewarding products that may be recyclable in theory but perform less well when processed through standard paper mills.

It argues that RAM should take greater account of the infrastructure packaging is actually likely to encounter and the quality and quantity of material ultimately recovered, rather than considering recyclability alone.

FPA comment: “This raises an important point about what modulation is ultimately intended to achieve. A methodology which influences packaging design and potentially significant producer costs has to reflect real-world outcomes as accurately as possible.

“The same principle lies behind concerns we have already raised about other aspects of RAM 2027: assessments need to be evidence-based, practical to demonstrate and applied consistently.

“Ultimately, the success of EPR should be measured not simply through ratings assigned to packaging, but through measurable improvements in collection, sorting and recycling”.

Pulpex opens first commercial paper bottle plant in Glasgow

Pulpex has opened its first commercial manufacturing facility for fibre-based bottles at Westway Industrial Estate in Glasgow, moving the technology from pilot-scale production into full commercial manufacture.

The new site has an initial capacity of up to 40 million bottles a year, with more than 90% of its available capacity for the current year already committed.

Pulpex says its bottles are made from sustainably sourced wood pulp, are designed to run on established filling infrastructure and can be recycled through existing household paper and card collection systems.

The Glasgow plant will also act as the reference site for Pulpex’s international licensing model, with manufacturing partnerships planned in Europe, India and the Gulf region.

The facility has been supported by investment from the UK National Wealth Fund and the Scottish National Investment Bank, which previously led a £62 million funding round for its construction.

Food Made Good Standard updated for 2027

The Sustainable Restaurant Association has launched an updated version of its Food Made Good Standard for hospitality businesses.

The revised standard has been developed following input from more than 50 experts and includes changes to its question set and scoring methodology, together with updates designed to reflect the EU’s new anti-greenwashing requirements.

The new global version will take effect from January 2027, while businesses operating in the EU have already begun using the revised question set.

The Food Made Good Standard assesses hospitality businesses across sourcing, society and environmental performance, including food waste, resource use and recycling.

Japan develops common recyclability test for flexible films

Japanese packaging companies Toyo Ink and DIC have developed what they describe as the country’s first common industry protocol for assessing the recyclability of flexible film packaging.

The protocol standardises how deinking, debonding and recycled-plastic quality are tested, addressing a problem whereby companies have historically used different test conditions and assessment criteria.

The protocol will be showcased at Tokyo Pack later this month.

UK

Packaging Scotland: Antalis uses life-cycle data to help customers assess packaging choices. Read more here

British Plastics Federation: Winners announced for the 2026 Horners Awards, recognising innovation in plastics, recycling and sustainability. Read more here

Waste360: Research challenges assumptions about how strongly consumers value recyclable packaging. Read more here

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

RESEARCH AND TECHNOLOGY

Paper Asia: Tetra Pak launches paper-based ice-cream wrapper containing up to 85% paper. Read more here

Packaging Insights: Duo Packaging launches graphene-enhanced PE film to boost strength and recycled content. Read more here

Packaging Europe: Tetra Pak launches ice-cream wrapper containing up to 85% paper. Read more here

Circular: Manufacturer develops ‘never seen before’ next gen flexible packaging. Read more here

Packaging Europe: SIG develops new bag-in-box fitment for foodservice dispensing applications. Read more here

Packaging Europe: Reusable shipping boxes redesigned to make returnable packaging easier to integrate into existing workflows. Read more here

EUROPE

Packaging Europe: European reuse operators launch an initiative to develop shared principles, harmonised labelling and an EU-wide deployment plan for reusable e-commerce packaging. Read more here

Packaging Europe: Brangs + Heinrich adds faster closure options and a larger format to its reusable shipping-box range, aimed at making reuse easier to integrate into existing logistics operations. Read more here

Packaging Europe: Tosca and Cabka develop a recycled and reusable Euro-size pallet designed for automated fresh-produce supply chains and future EU sustainability requirements. Read more here

INTERNATIONAL

Packaging Europe: Japanese companies develop common industry protocol for assessing deinking and debonding of flexible-film packaging. Read more here

Packaging Europe: Borouge invests in mechanical recycling capacity with planned additional output of 14,000 tonnes a year. Read more here

Waste360: Disneyland describes how purchasing, collection and processing data are being used to improve waste diversion. Read more here