The FPA Friday Digest

10 July 2026

The key development this week is PackUK’s confirmation of a 01 September deadline for large producers to correct and resubmit 2025 packaging data if they want changes reflected in Year 2 fees and Notices of Liability. With no further illustrative fees expected before confirmed 2026/27 figures are issued, the importance of accurate data shouldn't be underestimated.

We also look at continuing pressure over Wales’s approach to DRS, including calls for alignment with the rest of the UK, and a parliamentary question on scheme accessibility. Elsewhere, recent written answers underline the growing importance of data granularity, threshold fairness and clarity over how packaging reforms apply across different organisations and product categories.

The common thread is certainty. Businesses need clear rules, reliable data and practical implementation timelines if the reforms are to deliver political ambitions without creating unnecessary cost or complexity.

PACKAGING REFORMS UPDATE

PackUK sets deadline for Year 2 pEPR data corrections

PackUK has introduced a new 01 September 2026 cut-off for corrected 2025 packaging data to be reflected in Year 2 pEPR fees and Notices of Liability.

The deadline applies to producers who pay pEPR fees and gives businesses a five-month window from the original 01 April reporting deadline to correct and resubmit data. PackUK says this is intended to improve data stability, reduce in-year fee changes and allow confirmed 2026/27 fees and Notices of Liability to be issued later this year.

After 01 September, producers will still be expected to correct inaccurate data where necessary, but corrections submitted after the deadline will not affect Year 2 Notices of Liability or disposal fees.

PackUK does not intend to publish further illustrative Year 2 fees. The next fees published will be confirmed figures and will be used to calculate Notices of Liability. As in Year 1, producers will have 50 calendar days to pay, with the option to pay in instalments.

Further information is available from PackUK via GOV.UK, LinkedIn or the pEPR Helpdesk: EPRCustomerService@defra.gov.uk / 0300 060 0002.

FPA comment: “This is a significant operational deadline for producers. With no further illustrative fees expected before confirmed Year 2 liabilities are issued, businesses are advised to check their 2025 data and make any necessary corrections before the 01 September deadline to reduce the risk of unexpected fees".

 

PackUK publishes RAM 2027 comparison infographics

To support understanding of the changes to the Recyclability Assessment Methodology (RAM) for 2027, published last week and reported on in the previous issue of the Digest. PackUK has produced comparison infographics showing how RAM 2027 differs from RAM v1.1 across material categories. The graphics identify no major changes for steel, aluminium, wood and 'other' materials, but highlight changes for paper or board, fibre-based composite cartons, plastic flexibles, plastic rigids and glass.

Areas of relevance to foodservice packaging include coatings, silicone, foil, label coverage, adhesives, ethylene vinyl alcohol (EVOH), carbon black, polyethylene terephthalate (PET) thermoforms with non-PET multilayers and the treatment of flexible plastics. PackUK stresses that the graphics are a summary only and should be used alongside the full RAM 2027 materials assessment guidance.

IN BRIEF

BPF raises concerns over RAM 2027 treatment of flexible plastics

The British Plastics Federation has raised concerns over the treatment of flexible plastic packaging under the updated RAM 2027 methodology, warning that flexible plastics risk being penalised compared with other materials following the removal of the possibility of gaining a green rating.

Defra says packaging data is not held at product level

Defra has confirmed it does not hold data on the volume of plastic packaging used specifically for uncut fruit and vegetables.

In response to a written question from Tan Dhesi MP, Circular Economy Minister Mary Creagh said packaging data reported under the UK’s producer responsibility system is collected by packaging category and material type, rather than by individual food product. As a result, Defra has not made an estimate of plastic packaging used for uncut fruit or uncut vegetables in the past year.

The answer is relevant to wider questions about data granularity under pEPR. While category and material-level reporting supports scheme administration, it also limits the extent to which policymakers can assess packaging use, costs or design choices in specific product areas.

Defra rules out pEPR change for social enterprises

Defra has confirmed it is not currently considering a change to the treatment of social enterprises under pEPR.

In response to a written question from Patrick Hurley MP, Circular Economy Minister Mary Creagh said obligations are based on packaging placed on the market and statutory thresholds, rather than on a business model.

Packaging data file guidance updated

GOV.UK packaging data guidance has been updated to include time-period codes for 2026 and 2027. This is a practical compliance note for producers preparing or checking data submissions.

Defra pressed on DRS accessibility

Defra has been asked what steps it is taking to ensure the Deposit Return Scheme is accessible for people with disabilities and limited mobility.

In a written answer, Circular Economy Minister Mary Creagh said Defra has published an Equality Impact Assessment and worked with the Cabinet Office Disability Unit, the Government Equalities Office and disability groups, including Disability Rights UK.

Welsh DRS pressure grows as businesses call for UK alignment

Welsh food and drink businesses are continuing to press for Wales’s deposit return scheme to align with the rest of the UK, amid concerns that including glass could add cost, complexity and consumer confusion.

The issue has become increasingly urgent as the rest of the UK prepares for a DRS covering plastic bottles and cans from October 2027, while Wales has maintained its ambition to include glass.

pEPR exemptions remain based on turnover and tonnage

A written parliamentary answer has confirmed that Defra does not apply separate pEPR exemptions for social enterprises. Responding to Patrick Hurley MP, Mary Creagh said producer obligations are determined by turnover and packaging tonnage rather than business model.

ELSEWHERE ...

Waste carrier reforms move towards implementation

Defra is continuing work to replace the current carrier, broker and dealer registration system with a new environmental permitting regime. The reforms are intended to strengthen oversight of waste movements and tackle waste crime. This is worth monitoring for businesses that handle waste directly or rely on third-party waste contractors.

Digital waste tracking and waste crime

Manuela Perteghella MP asked about collaborative frameworks between Defra, law enforcement agencies and local authorities to support implementation and enforcement of Digital Waste Tracking, particularly in areas with high levels of illegal dumping.

Mary Creagh said Digital Waste Tracking is one of the major structural reforms under the Waste Crime Action Plan and will apply to waste operators across the UK. Defra is leading delivery with the Environment Agency, HMRC, the Home Office, police forces, local authorities, regulators and devolved governments.

WRAP gate fees report highlights shifting treatment costs

WRAP’s latest gate fees survey found that median gross MRF gate fees rose to £90 per tonne in 2025/26, while the median cost of treating separately collected food waste through anaerobic digestion fell from £24 to £13 per tonne. Circular Online reports that the findings come as councils and contractors prepare for household collection reforms and pEPR.

EUROPE ROUND-UP

EUROPEN calls for Circular Economy Act to address national EPR gaps

The European Organisation for Pakaging and the Environment (EUROPEN) has called for the forthcoming EU Circular Economy Act to address 'wide' performance gaps between national packaging EPR systems across the bloc.

The call follows a study commissioned by EUROPEN and conducted by CIRCPACK by Veolia, which found that binding recycling targets and harmonised reporting requirements under the Packaging and Packaging Waste Regulation will only deliver results if national EPR systems are able to collect, sort and recycle packaging at scale.

The study identifies infrastructure gaps as a major barrier, with sorting and reprocessing capacity described as insufficient across much of the EU.

EUROPEN argues that the Circular Economy Act should move Europe beyond fragmented national approaches by establishing a more harmonised and effective framework for EPR, potentially through a dedicated EU EPR Regulation.

CEFLEX Retailers call for PPWR grace period as August deadline approaches

The Circular Economy for Flexible Packaging (CEFLEX) has warned that rising EPR fees for flexible plastic packaging must translate into measurable improvements in recycling performance, rather than simply increasing producer costs.

The organisation argues that higher fees will have limited impact unless matched by investment in collection, sorting and recycling infrastructure.

FPA comment: "A relevant issue as the UK prepares for fee modulation from Year 2 of pEPR. Modulation should incentivise recyclability, not simply add cost where recycling systems are not yet capable of handling the material at scale".

INTERNATIONAL ROUND-UP

Oregon publishes first EPR implementation report

Circular Action Alliance Oregon has published its first annual report on the state’s paper and packaging EPR programme.

According to Waste360, the first six months of implementation saw producer-funded investment begin to roll out across Oregon’s recycling system. More than 2,900 producers are participating, with in excess of 409,000 tonnes of materials reported.

The Oregon programme is being watched closely as one of the first US packaging EPR schemes to move from policy design into operational delivery.

 

OTHER NEWS

UK

GOV.UK: RAM 2027 – overview. Read more here

letsrecycle.com: PackUK sets deadline for 2025 packaging data resubmissions. Read more here

Circular Online: CIWM to develop competence route for new waste permitting regime. Read more here

Packaging News: Deliveroo, Pho and Sheffield Hallam University team to 'rethink delivery packaging'. Read more here

letsrecycle.com: Keep Britain Tidy pilot cuts food and drink-related litter by 16%. Read more here

Hospitality & Catering News: One in six hospitality venues at risk of closure as sector unites behind VAT cut. Read more here

Packaging Gateway: Plastic waste report sharpens focus on supermarket packaging. Read more here

EUROPE

IOM3: European Commission clarifies plastic bottle recycling rules. Read more here

FoodBev Media: UK and Netherlands strengthen cooperation on circular economy finance. Read more here

Packaging Insights: CEFLEX urges EU policymakers to ensure rising EPR fees deliver higher flexible plastics recycling rates. Read more here

RTE: Ireland’s Deposit Return Scheme passes three billion returned bottles and cans, but operational issues remain. Read more here

FoodBev Media: UK and Netherlands strengthen cooperation on circular economy finance. Read more here

INTERNATIONAL

U.S. News & World Report: California introduces new rules replacing “sell by” labels on food packaging. Read more here

Label an Narrow Web: US lawmakers reintroduce legislation targeting PFAS and other chemicals in food packaging. Read more here

EXTERNAL EVENTS & PARTNER NEWS

Last chance to book for the Packaging News Sustainability Summit and Awards

There's still time to book for the Packaging News Sustainability & Impact Summit and Awards, taking place next Tuesday, 14 July, at the Kia Oval, London.

The FPA is pleased to be supporting the event as a sponsor.

The programme is closely aligned with the issues currently shaping the sector, including packaging EPR, DRS, Simpler Recycling, recycling infrastructure, circular design, reuse, carbon reduction, packaging data and the commercial realities of regulatory change.

The awards will also recognise businesses, projects and individuals making measurable progress in packaging sustainability.

Members who have not yet booked are encouraged to secure their place via the button below:

Date change for July Stakeholder Engagement Forum

Please note that the date to the next Circular Economy Stakeholder Forum meeting has changed from 07 July to 14 July – and unfortunately now clashes with the Packaging News Sustainability Summit. 

No registration is required, the Microsoft Teams link accompanying each forum will provide direct access to that meeting. Stakeholders are advised to check future communications for updated joining details in the event that the original link supplied below fails to work for the new date.

July Forum – Tuesday 14 July: 14:30 to 16:00 Link to access forum

FPA NEWS & EVENTS

FPA member survey closes today!

Today is the last chance for FPA members to share their views through a new member survey designed to help the FPA better understand members’ current priorities, pressures and expectations, and to ensure that its policy work, member communications, events and support services continue to reflect the needs of the businesses the association represents.

FPA members who have not received any of the emails containing the survey link should contact Lisa McGowan for a direct link to the survey.

 

Save the date: FPA 2026 Environment Seminar

The FPA’s 2026 Environment Seminar will take place on Thursday 05 November 2026 at Stationers’ Hall, London.

As in previous years, the seminar brings together expert speakers, industry voices and sustainability specialists for a day of insight, discussion and networking, exploring the environmental challenges and opportunities shaping the foodservice packaging sector.

In 2026, for the first time, the seminar will be open to both FPA members and non-members, with members benefiting from a lower ticket rate. Early bird pricing will also be available this year – full booking details to follow shortly.

To help inform early career talent and support the next generation of sector leaders, the FPA is introducing a new initiative entitled 'Young Emerging Professionals (YEP)' for employees under 30-years-old and working within an FPA member company. Up to 10 free places at the Environment Seminar will be available under this initiative.

The programme and speaker line-up are currently being finalised, so watch this space for further announcements and for additional details about the new FPA YEP initiative.

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. 

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