The FPA Friday Digest

FPA takes its five priorities directly to Andy Burnham and Angela Eagle

The FPA has now written to Prime Minister Andy Burnham and Environment Secretary Dame Angela Eagle setting out five priorities for packaging reform and offering to work with the new government to deliver a fairer and more effective system.

The letters build on the concerns outlined in last week’s Digest, calling for greater confidence in packaging extended producer responsibility, stronger enforcement, evidence-led policymaking, regulatory certainty and closer partnership between government and industry.

On pEPR, the FPA is seeking an independent review of producer registration and enforcement, greater transparency around the data, assumptions and methodologies used to calculate fees, and action to ensure all obligated producers contribute fairly. It has also urged ministers to consider whether recyclability fee modulation should proceed before sufficient confidence has been established in the system underpinning it.

The association warns that poorly designed or inconsistently implemented regulation risks penalising visible, compliant UK businesses while creating opportunities for free-riding and market distortion. It argues that packaging policy should assess whole-system environmental outcomes and recognise packaging’s essential role in protecting food, supporting public health and reducing food waste.

The letters also highlight the need to consider the cumulative effect of policies across government. Although Plastic Packaging Tax is administered by HMRC rather than Defra, the FPA says it should not be viewed in isolation from pEPR, Simpler Recycling, recyclability assessments and wider circular economy policy.

The FPA has stressed that it is not seeking to slow environmental reform. Its aim is to ensure reforms are based on reliable evidence, implemented to realistic timescales and capable of supporting investment in UK manufacturing, recycling infrastructure and packaging innovation.

FPA comment: “Packaging reform can support both growth and better environmental outcomes, but only if businesses can trust the data, understand the direction of travel and invest with confidence. We are asking the new government to work with industry to refine the system, strengthen its integrity and ensure responsible UK businesses are not disadvantaged”.

Emma Hardy handed circular economy brief

Defra has finally confirmed that Minister of State Emma Hardy will be responsible for the circular economy and waste crime.

The confirmation came in an update distributed by Defra’s Circular Economy team yesterday rather than through the ministers’ official GOV.UK pages, which at the time of writing still do not set out their detailed portfolios.

Defra has also confirmed the wider allocation of portfolios. Jenny Riddell-Carpenter will oversee nature, biodiversity and climate adaptation; Stephen Morgan will be responsible for farming and food; and Baroness Hayman of Ullock will cover trade, biosecurity and animal welfare.

Although packaging and resources are not named individually, the allocation of the circular economy portfolio to Emma Hardy establishes her as the minister expected to lead Defra’s collection and packaging reforms following Mary Creagh’s departure.

The department has separately announced that Becky Shrubsole began work this month as its new Director of Circular Economy. Shrubsole has previously held senior roles at Defra and the Ministry of Housing, Communities and Local Government and brings experience of working across central government, devolved administrations, local authorities and business.

As Director, Shrubsole will provide senior civil-service leadership for the circular economy agenda, while ministerial responsibility and political accountability will sit with Emma Hardy.

FPA comment: “We welcome confirmation that Emma Hardy will take responsibility for the circular economy, although it should not have taken nine days for industries implementing major and costly reforms to be told who their minister was.

“There is now an urgent need for early engagement and clear leadership on pEPR, packaging collections, infrastructure and the delayed Circular Economy Growth Plan. We also welcome Becky Shrubsole’s appointment and look forward to working with both the ministerial and official teams”.

Flexible plastics sector calls for transition plan after collections delay

The Flexible Plastic Fund has called for an urgent, phased transition plan following Defra’s decision to postpone mandatory household collections of flexible plastic packaging in England until 1 April 2030.

Rather than allowing the next three years to become a pause in delivery, the Fund wants government, producers and the waste sector to establish a roadmap covering local authority readiness, infrastructure requirements, responsibilities and measurable milestones.

It is also seeking greater transparency over how producer fees collected through pEPR will be used to support the future rollout of flexible-plastic collections, together with continued recognition of front-of-store collection schemes while nationwide kerbside services remain unavailable.

The reaction across the waste and packaging sectors has been divided. Producers, recyclers and organisations including Ecosurety and RECOUP have warned the delay could undermine businesses that invested against the original timetable. In contrast, Packaging News reports that Biffa has welcomed the additional preparation time, reflecting concerns among some waste operators about the lack of sufficient sorting capacity, reprocessing infrastructure and viable end markets.

In related news, The Canary reports analysis by BusinessWaste.co.uk suggesting the three-year delay could affect more than 450,000 tonnes of flexible plastic by 2030 if material continues to enter general waste streams. Using WRAP CarbonWARM2 figures and Defra data on residual waste treatment, the article estimates the potential carbon difference between recycling and disposal could be between 734,600 and 845,800 tonnes of CO2e.

FPA comment: “The call for a properly managed transition plan is sensible. A delay cannot simply leave a policy vacuum until 2030. Government should use this period to coordinate collections, sorting, reprocessing and end-market development, with clear milestones and transparency over how producer funding will improve the system.

“Businesses that have invested against the previous timetable also need clarity over the continued role of retailer take-back schemes and assurance that they will not be penalised for the absence of universal kerbside collections”.

Fibre packaging manufacturers urge ministers to rethink pEPR

The Alliance for Fibre-Based Packaging has urged the new government to refine the pEPR framework, warning that its current design risks discouraging investment in lower-carbon and recyclable packaging innovation.

Alliance representatives delivered their position to Downing Street, calling on ministers to redesign pEPR fees so they properly incentivise sustainable material choices, introduce transparent and evidence-based Recycling Assessment Methodology classifications, publish the evidence underpinning fee and recyclability decisions, and support simple and consistent household recycling collections.

The Alliance argues that uncertainty over fees and future RAM classifications is affecting investment decisions and could reverse established moves from fossil-based plastic towards fibre-based alternatives. It has also raised concerns about whether broad assumptions applied to fibre-based composite packaging accurately reflect the recyclability and end-of-life routes of different formats.

The intervention echoes wider concerns identified through the FPA’s own research into the operation and integrity of pEPR. The research highlighted potential gaps in producer registration and limited visibility over whether all obligated businesses are contributing, raising concerns that a disproportionate share of the cost could fall on established, compliant companies.

The FPA has previously called for an independent review of producer registration and enforcement, greater transparency around fee modelling and assumptions, and stronger assurance that the data underpinning the system is sufficiently robust before recyclability fee modulation is introduced.

Although the Alliance’s work is separate from the FPA research, both interventions underline the importance of ensuring pEPR rewards genuine packaging innovation, treats different formats fairly and does not place responsible UK manufacturers at a competitive disadvantage.

FPA comment: “The Alliance’s intervention reinforces the need for pEPR and RAM to be based on transparent evidence and to provide credible incentives for investment. The FPA’s own research has also raised important questions about the integrity of the producer base and whether all obligated businesses are contributing fairly. These issues need to be addressed together if the system is to command industry confidence and deliver its intended environmental outcomes”.

Regulators publish new pEPR technical interpretations 

The UK environmental regulators have published version 8 of their agreed positions and technical interpretations for pEPR.

The National Packaging Waste Database now directs producers and compliance schemes to:

• use version 7 for packaging-data submissions relating to 2025; and
• use version 8 for 2026 data submissions onwards.

The documents set out the shared interpretations adopted by the Environment Agency, Natural Resources Wales, the Northern Ireland Environment Agency and the Scottish Environment Protection Agency.

View the regulators’ agreed positions and technical interpretations

The NPWD guidance page explicitly distinguishes version 7 for 2025 submissions from version 8 for 2026 onwards.

DRS return-point exemptions widened

Exchange for Change has broadened the circumstances in which smaller retailers can seek exemption from operating a Deposit Return Scheme return point.

Urban grocery retailers with between 100m² and 199m² of sales space, and rural retailers below 200m², may apply for a size-based exemption. Applications may also be considered where adequate alternative return facilities exist nearby or where access, building design, heritage restrictions or utility constraints make a return point impractical.

This is in addition to the automatic exemption for urban grocery retailers below 100m², which do not need to apply or register with Exchange for Change. Any application-based exemption will remain subject to sufficient local return-point coverage and individual assessment.

Circular economy must move beyond recycling

The Welsh Government says it is "optimistic" that a Deposit Management Organisation (DMO) for its Deposit Return Scheme (DRS) will be appointed "in short order", marking an important step towards the planned October 2027 launch.

Speaking in the Senedd, Environment Secretary Llyr Gruffydd described the appointment as a "critical milestone", with industry widely expecting Exchange for Change – already appointed to operate the DRS in England and Northern Ireland – to be selected for the Welsh scheme.

However, ministers have also reaffirmed their commitment to retaining glass within the Welsh DRS, despite continued opposition from much of the drinks, retail and hospitality sectors. Gruffydd argued that reopening the debate would create further uncertainty and delay implementation, adding that Wales remained committed to building a system that prioritises reuse alongside high recycling performance.

Industry bodies continue to disagree. The Wine & Spirit Trade Association warned that time is running short to finalise a workable scheme and repeated concerns that including glass could increase costs, reduce consumer choice and create operational challenges for businesses trading across UK borders.

US packaging EPR programmes face questions over fees and governance

As pEPR expands across the US producers and local authorities are raising concerns about how fees will be set, how funds will be used and who will decide whether packaging is recyclable.

Seven states have now passed packaging EPR laws, but differing rules and implementation models are creating added complexity for businesses operating nationally.

The debate mirrors concerns in the UK, where confidence in EPR will depend not only on moving costs to producers, but also on transparent governance, reliable data and clear accountability.

UK

The Grocer: Packaging tax may force mass return to plastic, PM warned. Read more here

The Grocer: Is the government going soft in its war on plastic? Read more here

Packaging News: Biffa welcomes delay to mandatory flexible collections. Read more here

Circular Online: Why local action is key to tackling waste crime. Read more here:

ENDS Report: Hardy to stay at Defra as ministerial reshuffle underway. Read more here

Circular Online: Construction has begun on a £35m SUEZ Anerbic Digestion facility. Read more here

letsrecycle.com: What does 'Manchesterism' mean for waste and recycling? Read more here

Packaging Scotland: Alupro has published its 2025 impact report, highlighting the rolw of collaboration in driving circular packaging progress. Read more here

Sustainable Packaging News: Fom Amber to Red – why the UK's RAM 2027 guidance will cost unprepared brands dearly. Read more here

EUROPE

Freshfields: The 'E' of ESG – an overview of PPWR. Read more here

INTERNATIONAL

Packaging Gateway: Vague packaging claims may hurt buying decisions, claims study. Read more here

INTERNATIONAL

Packaging Gateway: Barrier coatings may be packaging's quiet revolution. Read more here

Chemistry World: Chemical recycling plants closing in EU and US. Read more here

Fresh Fruit Portal: New EU produce packaging rules put US exporters on the clock. Read more here