The FPA Friday Digest
14 August 2026
This week’s Digest is dominated by the move from policy design to delivery, with several major packaging reforms entering a more operational phase.
PackUK has set out its priorities for Year 2 of pEPR, putting data stability, certainty and transparency at the heart of its approach and confirming plans for a single Notice of Liability by the end of November. This comes as Defra has issued a corrected version of its 2026 packaging data generator, while new Environment Agency proposals set out how enforcement could apply across pEPR, Digital Waste Tracking and DRS.
In Europe, the Packaging and Packaging Waste Regulation began applying on 12 August, bringing immediate requirements including new PFAS restrictions for food-contact packaging. But implementation is already exposing practical challenges, with businesses reporting uncertainty over how compliance should be demonstrated in the absence of a harmonised testing methodology.
Elsewhere, we look at the latest PRN market signals, concerns around divergence in the Welsh DRS and new tools for assessing plastic packaging recyclability in North America.
PACKAGING REFORMS UPDATE
PackUK puts data stability at centre of Year 2 EPR plans
PackUK has said greater stability, certainty and transparency will be central to its approach to the second year of packaging EPR, as it prepares to issue producers with a single Notice of Liability for 2026/27.
In a letter shared with industry trade bodies, new COO Simon Woods said improving data stability is a key operational priority, arguing that stronger-quality data is essential to fair fee calculations, avoiding late adjustments and giving businesses greater confidence when planning and investing.
The message reinforces PackUK's newly updated 2026/27 operational plan, which forecasts total fee recovery of £1.558bn, comprising £1.47bn in local authority disposal costs, £28m in administration costs and a £60m impairment provision.
PackUK has set 1 September 2026 as the deadline for resubmissions of 2025 packaging data that are to be reflected in Year 2 liabilities. Subject to regulators across all four nations completing their data-assurance work, it intends to issue a single Notice of Liability by the end of November, alongside confirmed Year 2 fees.
Woods said the approach reflects lessons learned from the first year of the scheme, when late data changes contributed to uncertainty and adjustments in producer liabilities. Producers brought into compliance after the main notices have been issued would receive individual Notices of Liability before the end of the financial year rather than triggering a wider recalculation.
He also committed PackUK to maintaining regular dialogue with producers, compliance schemes, trade associations and regulators as the scheme develops.
FPA comment: “The emphasis on data quality, stability and transparency is welcome and reflects issues the FPA has consistently raised throughout the development of pEPR. Moving to a single Notice of Liability should give producers greater certainty, but it also makes it even more important that the underlying data is complete, accurate and captures all obligated producers before fees are finalised. We look forward to continuing our dialogue with PackUK".
Digital waste tracking timetable clarified as
Environment Agency consults on PRO enforcement
Government has clarified that mandatory digital waste tracking for waste receiving sites in Northern Ireland will begin in January 2027, bringing it in line with Scotland. Waste receivers in England and Wales are due to begin using the service mandatorily from October 2026. The digital service has been available for public testing since April.
The clarification comes as the Environment Agency has launched a consultation on changes to its enforcement and sanctions policy. The proposed changes set out its enforcement approach for the 2024 packaging producer responsibility regulations and proposed approaches for the first phase of Digital Waste Tracking and the Deposit Return Scheme. The consultation applies to England. It opened on 10 August and will run until 04 October.
Useful links:
NI Department of Agriculture, Environment and Rural Affairs – Digital Waste Tracking
FPA comment: "Businesses need absolute clarity about what is required, when it is required and how compliance will be assessed. Digital waste tracking has the potential to improve transparency and confidence in the waste system, but implementation and enforcement must be proportionate and consistent, particularly while businesses and regulators are bedding in new systems”.
PRN data points to tighter markets for plastic, steel and wood
The first more complete picture of Packaging Recovery Note supply under the new reporting system suggests several material markets could remain tight during 2026.
Analysis by Ecosurety of the first six months of data indicates that, once carry-in PRNs from 2025 are included, glass and aluminium are currently ahead of the level required for annual compliance, while paper and fibre composite are close. Plastic, wood and steel appear considerably tighter.
There are important caveats. A number of accredited organisations have yet to provide complete data, while changes to the point at which Packaging Export Recovery Notes can be issued initially delayed supply from export-heavy streams such as plastic. Ecosurety nevertheless expects upward pressure on PRN prices for plastic, steel and wood in the short term.
FPA comment: “The improved visibility is welcome, but continued uncertainty over supply demonstrates why timely, accurate data is so important to a functioning PRN market. Producers need confidence that prices reflect genuine recycling performance and available capacity rather than reporting delays or avoidable market uncertainty”.
WRAP sets out flexible plastics strategy following collection delay
WRAP has set out a new strategy for flexible plastic packaging, calling for collection, sorting, recycling capacity and end markets to be developed together as England prepares for the delayed introduction of household film collections in 2030.
Published through the UK Packaging Pact, the Films and Flexibles Strategy argues that simply collecting larger volumes of flexible packaging before sufficient sorting and reprocessing capacity exists could increase costs and undermine public confidence in recycling.
The scale of the challenge remains significant. Fewer than 5,000 tonnes of the estimated 383,000 tonnes of consumer plastic film placed on the English market each year are currently recovered through front-of-store collection points, while existing UK reprocessing capacity is estimated at between 25,000 and 50,000 tonnes annually. By contrast, collection volumes could exceed 200,000 tonnes by 2030.
WRAP says the additional time created by government’s decision to delay mandatory kerbside collection of plastic films and flexibles until April 2030 should be used to develop the necessary infrastructure and markets. It is also calling for packaging design guidance, Recyclability Assessment Methodology ratings and on-pack recycling information to be aligned with the systems actually available to consumers.
The strategy will now be taken forward by the UK Packaging Pact’s Films and Flexibles Industry Expert Group, which will develop interim milestones ahead of 2030. A separate FlexCircular project is expected to report later this year on the investment required to process up to 400,000 tonnes of post-consumer flexible packaging annually.
FPA comment: “The delay to flexible plastics collections must be used productively. Collecting material without sufficient sorting, reprocessing capacity and sustainable end markets simply moves the problem further down the chain. The focus now needs to be on creating a joined-up system that gives producers confidence that packaging designed for recycling can actually be collected and recycled at scale”.
IN BRIEF
Defra replaces EPR data generator after RAM error
Businesses that downloaded Defra's 2026 packaging data file generator before 12 August are being told to replace it with a corrected version. Defra says the generator published on 24 July contained an error in the ram–rag–rating column used for RAM reporting. The department has now uploaded an amended file.
ELSEWHERE ...
Drinks sector warns Welsh DRS divergence could restrict product choice
Drinks industry bodies have renewed warnings that Wales’s decision to pursue different arrangements for glass within its Deposit Return Scheme could lead some suppliers to reduce the range of wines, spirits and beers available in the Welsh market.
The warning, reported by the Telegraph, centres on the additional complexity and cost associated with operating a Welsh system that ultimately differs from the DRS being introduced in England, Scotland and Northern Ireland. Industry representatives have warned that smaller producers and importers in particular could decide that supplying Wales is no longer commercially viable.
Wales’s DRS launches on 01 October 2027, but glass containers will initially be subject to a four-year transition. Until 30 September 2031 they will carry a zero-pence deposit and be exempt from DRS labelling requirements, although they can still be accepted at return points. Full glass requirements would follow from October 2031.
Aldi and Arla trial digital tracking of milk bottles
Aldi and Arla have begun a new operational pilot using Polytag's invisible UV tags to follow milk bottle packaging through the recycling system. Fluorescent tags printed onto wrap-around labels can be detected at participating recycling facilities, giving the companies data on where and when packaging enters the recycling stream.
Suez warns procurement changes could weaken environmental benefits
Suez Recycling and Recovery has warned that planned changes to the way social value is assessed in major public procurement contracts risk overlooking environmental and wider community benefits delivered through waste and recycling contracts.
From January 2027, the social-value weighting applied to central government contracts worth more than £5 million is set to increase from 10% to 20%. Suez has welcomed the increased emphasis but argues that concentrating the assessment on employment and skills risks undervaluing areas including responsible sourcing, biodiversity, carbon reduction and wider community programmes.
EUROPE
PPWR kicks in across the EU as businesses grapple with PFAS compliance
The EU Packaging and Packaging Waste Regulation began applying across the bloc on 12 August, bringing its first substantive requirements into effect – including new limits on PFAS in food-contact packaging.
While many of the PPWR's major recyclability, recycled-content, reuse and packaging-minimisation measures will not apply until later years, the European Commission says the 12 August milestone marks the beginning of phased implementation. Requirements now applying include restrictions intended to prevent exposure to PFAS through food-contact packaging, while harmonised labelling is expected from 2028 and many of the Regulation's wider circularity measures from 2030.
Although PPWR is an EU regulation, the research suggests its influence is extending beyond packaging destined specifically for the EU, as businesses seek to standardise formats across different markets rather than operate multiple packaging specifications.
The scale of the potential impact on UK businesses is highlighted by new research reported by Circular Online. A survey of 200 British manufacturers and suppliers operating in non-food supply chains found that 93% had already been affected by PPWR or expected to be. Some 16% said they had already reformatted packaging to comply, 39% were making changes and a further 32% were reviewing and assessing their packaging formats.
Implementation of the PFAS requirements is already creating practical difficulties. The Grocer reports widespread supplier confusion around the new rules, while Food and Drink Federation guidance highlights there is currently no harmonised EU testing methodology for PFAS in food-contact packaging. The limits apply to the complete packaging unit, including inks, coatings and adhesives, whether PFAS are intentionally added or not.
Until a harmonised testing protocol is established, FDF advises manufacturers to seek appropriate assurances from suppliers and consider analytical testing where necessary, while cautioning that screening techniques such as total-fluorine analysis cannot by themselves demonstrate compliance with each of the PPWR thresholds.
The requirements also have direct implications for UK companies supplying Europe and Northern Ireland. UK food and drink businesses placing packaging on the EU market must now be able to demonstrate conformity with the requirements that have entered into application, while most PPWR provisions also apply to packaging placed on the Northern Ireland market under the Windsor Framework.
UK government guidance updated on 12 August also warns exporters that PPWR applies to service packaging as well as primary, secondary and tertiary packaging, and that non-compliant packaged goods could be rejected at EU borders.
Useful links:
European Commission: New EU packaging rules start to apply, including restrictions on PFAS in food-contact packaging
Business.gov.uk: UK Government exporter guidance
FPA comment: “The industry has been preparing for PPWR for some time, but the difficulties around PFAS demonstrate the challenge businesses face when legal requirements take effect before all of the practical tools needed to demonstrate compliance are in place. Companies need clear, workable and harmonised guidance if PPWR is to achieve its objectives without creating unnecessary barriers to trade”.
Commission proposes harmonised packaging producer reporting
The European Commission has opened consultation on draft rules designed to standardise the way packaging producers register and report information under the PPWR across EU Member States.
The proposed implementing regulation would establish common electronic formats for producer registration, EPR compliance declarations, producer responsibility organisation certificates and information relating to authorised representatives. It also proposes different reporting templates around a 10-tonne annual packaging threshold and material-level reporting for composite packaging.
Feedback is open until 10 September. The measure is intended to reduce differences between national producer registers as the PPWR's extended producer responsibility provisions are implemented.
French association warns against over-interpreting PPWR supplier duties
French plastic packaging association Elipso says packaging manufacturers are receiving a growing number of requests from customers for information and assurances that go beyond what is currently required under the PPWR.
The association says some brands and retailers are asking suppliers for extensive substance information, testing and definitive recyclability grades as part of preparations for EU declarations of conformity. Elipso argues that packaging suppliers have obligations to provide relevant information but that the final responsibility for conformity rests with the party classified as the manufacturer under the Regulation – typically the brand owner or packager in the circumstances it describes. A number of future technical requirements can't yet be fully assessed because the necessary implementing measures are still in development.
INTERNATIONAL
APR launches digital packaging recyclability assessment tool
The US Association of Plastic Recyclers has launched a digital tool designed to assess the recyclability of complete plastic packages rather than individual components in isolation.
Developed with packaging software company Recyda, the APR Design Assessment Tool applies APR's Design Guide and classifies packaging as 'Preferred Design for Recycling', 'Tolerated but Needs Improvement', 'Non-Recyclable' or 'Requires Testing'. It can also assess packaging against California's SB 343 recyclability labelling requirements and includes options designed to support EPR assessments.
OTHER NEWS
UK
GOV.UK: Environment Agency stops waste operation at Wolverhampton site. Read more here
MRW: Northern Ireland eyes January 2027 mandatory digital waste tracking launch. Read more here
letsrecycle.com: A new dawn has broken for PRNs? Read more here
Packaging Gateway: How eco-modulated EPR fees are changing packaging economics. Read more here
Circular: CIWM competence scheme moves into delivery as waste permitting reforms become law. Read more here
letsrecycle: Simon Woods joins as COO of PackUK. Read more here
RESEARCH AND TECHNOLOGY
Packaging Insights: Closing the data gap – packaging suppliers advance end-to-end traceability. Read more here
Sustainable Packaging News: Kyungpook National University Team Identifies Two Enzyme-Surface Principles Governing PET-Degradation Performance. Read more here
Sustainable Packaging News: BOPP films continue to advance despite a constantly changing regional landscape. Read more here
Associated Press: PHA alternatives for cutlery and food packaging. Read more here
Interplas Insights: ReVentas secures £3.5m Scottish Enterprise grant – focusing on difficult-to-recycle plastics such as films used in food packaging. Read more here
Technology Networks: Smart hydrogel packaging tells you if food is still fresh. Read more here
Packaging Insights: Metsä Group has invested €25 million (US$28.8 million) in a line for the production of Muoto fiber foodservice packaging. Read more here
Packaging Insights: Nanofiber packaging film can extend kiwifruit shelf life, study finds. Read more here
EUROPE
Deloitte: A new era for packaging under the PPWR, applicable from 12 August. Read more here
letsrecycle: PPWR rules come into effect across the EU. Read more here
ChemLinked: EU draft harmonises packaging producer register reporting. Read more here
ESM: French Packaging Association calls for PPWR rules to be followed. Read more here
Packaging Gateway: EU packaging waste rules begin phased rollout with PFAS restriction. Read more here
INTERNATIONAL
Global Trade Magazine: How plastic and PFAS rules are redrawing food packaging sourcing. Read more here
Plastics News: HHS seeks public disclosure of food packaging chemicals in MAHA-backed move. Read more here
FPA NEWS & EVENTS
Put your brand at the heart of the FPA Environment Seminar
Sponsorship opportunities are now available for the FPA Environment Seminar, taking place at Stationers’ Hall, London, on 5 November.
One of the FPA’s key annual events, the seminar is expected to bring together around 120 senior leaders, technical specialists, policymakers, practitioners and industry professionals to explore the environmental policy, regulation and practical challenges shaping the future of foodservice packaging.
For the first time this year, the event is also being promoted beyond the FPA membership, creating an even broader opportunity for sponsors to connect with manufacturers, distributors and wholesalers, alongside prospective customers, sector partners, policymakers and other stakeholders.
A limited number of Gold, Silver and Bronze partnership packages are available, offering varying levels of visibility before, during and after the event. Businesses can also support individual elements of the day, including lunch, coffee breaks, the drinks reception, lanyards and delegate materials.
You'll find details of our sponsorship options in this document, which outlines a range of opportunities to suit different budgets. These will be allocated on a first-come, first-served basis, so if you would like to secure your preferred package, please get in touch as soon as possible. Packages start from £250 + VAT.
Delegate tickets will be available to purchase shortly.
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
2026 UK Packaging Awards – have you booked your place yet?
The finalists have been announced and bookings are open for the 2026 UK Packaging Awards, taking place at the Hilton Park Lane, London, on Wednesday 07 October.
Now in their 21st year, the awards bring the packaging industry together to celebrate excellence, innovation and achievement across the supply chain. Following a sell-out event in 2025, tables are expected to be in high demand.
The evening will include a networking drinks reception, three-course gala dinner, awards ceremony and afterparty entertainment. Premium and standard tables for 10 or 12 guests are available, while the organisers can also arrange bookings for smaller groups.
Do you know a business that should join the FPA?
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FPA members receive early sight of this Digest on Thursday evenings, prior to distribution each Friday morning, and can view an archive of previous Digests within their FPA Dashboards or via this link