PPWR and the Future of Packaging Sustainability

The Future of Packaging Sustainability and PPWR

So on behalf of the Food and Drink Federation, we're really pleased to welcome you to this session on PPWR and the future of packaging sustainability. It's a really timely conversation and as we move further into 2026, this is one of the top issues for our members. What on earth is happening with PPWR?

Ellena Andrews   1:19
So today's session will be looking at the direction of the EU packaging and packaging waste regulations or PPWR. I don't know which is less of a mouthful to say, but together these are not isolated developments. They represent a structural shift in how sustainability is regulated, moving from voluntary ambition towards mandatory system change.

Charlotte Davies   1:20
But.

Ellena Andrews   1:41
We're delighted to be joined by our colleagues from Beyondly today who will help unpack what this means on the ground and then I'll come back towards the end to have a Q&A session. So if you have any questions, please do either get thinking about them, pop them in the Q&A portion, which you should see at the top of your screens.
So with that, we'll get started and I'd like to welcome Charlotte Davies and Michael Jones. Thank you.

Charlotte Davies   2:09
Thank you and good morning everybody. Welcome. Thanks for joining us. Yeah, without further ado, we'll kick off on our PPWR, UKPR and sort of packaging sustainability focus session today.
Right.
So hopefully many of you are already familiar with who Beyond Lee are, but if you've not come across us before, we are a B Corp environmental consultancy and compliance scheme. We're actually entering our 20th birthday this year. So yeah, 20 years have flown by. I definitely have not been there from the beginning. And essentially, we share our knowledge with businesses to help them become more confident about environmental choices, be that in
compliance, consultancy, regulation or sustainability. So a full 360 sort of service range in environmental services. And we're based up in Skipton, North Yorkshire, but we help customers with compliance in the UK and internationally, so across Europe and the US. So quick.
scan over some of our services there. We've got the compliance on the left hand side, packaging, we batteries focused and then a little bit of carbon compliance as well in ESOS and SECR. We have lots of the consultancy services sort of ranging from bespoke projects to more set ones like product carbon footprint, 0 waste to landfill, B Corp support.
And then finally, a growing area of our service range, which is our data services in packaging, we and batteries. So whether that's helping you to gather that data, review that data or report that data, it's sort of a well-rounded section. So on to our agenda today, we're going to really focus on what's been going on
in the UK with our EPR reform and how that's kind of looking at the moment. We're then going to sort of look more broadly into the EU, focusing on PPWR and a lot of the different requirements that are coming up over the next couple of years and what we know is finalised, what we're expecting to see as well.
So you'll notice these little symbols, the flags at the bottom. We've just tried to put them on the slides just so it's really clear which part relates to what, because sometimes it can be a bit confusing with all the different terminology and different regulations and things like that. So for those of you that
I haven't met either Michael or myself. I work in our resource efficiency and circularity team, so supporting businesses with some of those services I showed on the previous slide, and some bespoke research or bespoke projects for businesses looking to increase their circularity, resource efficiency and material use. And then I'm joined by Michael. I don't know if you want to jump in, Michael, and do a bit of an intro.

Michael Jennings   4:49
Hello!
Yes, so I'm a policy and public affairs advisor, so if you've got any questions or want any details on policy, then I'm the person to go to.

Charlotte Davies   5:01
So let's get started. So I think first up we're going to focus on UK packaging and I'll hand you straight back to Michael because he is our policy guru after all.

Michael Jennings   5:11
Thank you very much. What a lovely intro. So quick, quick round of what's been happening. So what is EPR? So around since the late 90s, the old producer responsibility system for packaging wasn't really working. This previous system was only picking up around 20% of the costs of dealing with waste packaging.
So now we have a new system and producers are picking up these costs. Household waste collection and sortation costs have now swapped from local authorities, Reid, consumers, to producers. And why? What is this purpose? So by moving these
these costs, putting them to people putting the packaging on the market, we are driving producers to develop lighter, optimised and more recyclable packaging. Good for everyone in the long term, hopefully.
And we've had a really busy year in 2025 with the PEPR getting into full swing, though it's not been without its hiccups, delays, reporting issues, data gathering and collection issues. But importantly, we have had improved consultation and dialogue with government.
and up and down the supply chains to make sure that these regulations are working the way they should be. We also have the first invoices under the new regulations sent out to producers last October, which definitely took a lot of people by surprise.
Some key points for the coming year, just going to highlight a couple. So for EPR, we have the next recyclability assessment methodology, RAM 2027, and this will be published in July this year for packaging you are placing on the market in 2027.
We're going to have this new simplified naming system for the RAM, which will directly link that version of the RAM to the year of packaging data, which applies. It could get really confusing if we were talking about RAM 1.1, 2.3, 6.9. So having RAM 27 for the year of 27, RAM 28 for the year of 28 is definitely going to make it a lot easier for you guys moving forwards.
And hopefully we're going to see an update from the government on mandatory labelling as well later in this year, and we'll come to that later in the webinar. Moving on to fees, we already had a first look at the 2026 base fees just before Christmas, and these are expected to be confirmed in April.
And then we'll get our first look at potential 2027 fees at the end of this year. A note on that, there will be a separation of fees for rigid and flexible plastics for the first time, which is going to separate the costs of dealing with those different materials.
The circular economy growth plan is still just on the horizon, just out of reach, and hopefully will be published soon. Fingers crossed, we will find out. And finally, in March, we will have year two of simpler recycling in England, which is going to bring unified waste collections across all households and businesses in the UK.

Charlotte Davies   8:22
Just a quick question with the circular economy growth plan, are we expecting that to have any impact on packaging materials or are we have we obviously seen most of EPR taking place?

Michael Jennings   8:24
Yes.
Kay.
Most of the packaging stuff I think has taken place. There will be hopefully a section in there, but I think it is headlined agri-foods and packaging. So I don't know if there's going to be more farming folks on that, but the majority of the packaging reforms are now in place. I think we'll come to this in a couple of slides.
and the ball is rolling on all of those. So fingers crossed, no major curve balls, we haven't foreseen for the packaging front at least.
So I know that there is a lot going on in the world of packaging at the moment, so a quick update on the RAM, or the recyclability assessment methodology, and associated fees. So like I said, just before Christmas, we had a first look at the potential 2026 base fees, which for the first time included modulation. From those first illustrative fees,
we can see there is a confirmed 20% markup on the base fee for packaging with a red rating under this methodology, with the current modelling suggesting a 9% saving for green rated packaging. We are expecting a couple of adjustments to these figures before the confirmed fees later in the year.
but it is a good place for producers to start planning. And you can see in the darker box there, for future years, this red rated packaging is going to increase in costs, so 20% affinity.
This year, 60% double year after that, etc, etc. Most probably seeing that increasing with that green reduction, depending on the amount of extra money raised from the red packaging. So more packaging rated red, the cheaper the green packaging will be and vice versa.
Moving on to the right there, for fee modulation in the UK currently based on packaging recycling, you can see highlighted in green, but from 2028 there are those other potential areas of focus that could affect modulation, such as the environmental impact of creating, transporting, use, disposal, recycling of packaging, along with renewed focus on reusability and packaging minimisation.
to reflect what's happening in Europe. So if you are planning on making any changes to a packaging in the near future, while we don't have any details on these areas as of yet, they are worth keeping at the forefront of your mind.
And then for the yearly development of the RAM as well, because this is a yearly review process of this living methodology, the government did the RAM roadmap published by PACT UK, which does lay out the areas of focus for the RAM development over the coming years. So some key points there include reviewing language and definitions based on user feedback. There's been a lot of user feedback.
the potential to add in previously removed data points, and then we've got international alignment, alignment with similar recycling, and of course, in-depth reviews of each material, which will be starting with fibre-based composites. So again, we know there is a short time frame between the updated RAM being published around July and packaging
being placed on the market six months later. But the RAM roadmap does outline what areas are being developed immediately and which are being looked at in a few years so you can plan when to tackle any changes to your packaging with as little disruption as possible. And a reminder for everyone, the packaging placed on market in 2026,
So this year should be assessed against the RAM version 1.1, the same as your 2025 packaging data. And then for 2027, we'll have that new RAM 27, which will be released around July.

Charlotte Davies   12:07
Great to keep it the same, just so we've got that ease for the first two years, I think, for producers.

Michael Jennings   12:11
Yeah. I mean, hopefully as well when the RAM is updated, it's going to be small points here and there. So it won't be a complete overhaul and have everyone tearing their hair out again like we did last year. So zooming out, looking at the general state of play in the UK, there are those two core areas to look at for 2026.
Operational change, so how waste is collected, tracked and managed, and then packaging, reporting and cost mechanisms, so what you report and what you pay. Starting with the operational considerations, we have the household waste collection reforms, similar recycling in England and related in the other nations. So this is going to bring greater consistency in collections across the UK and higher expectations of what is
practically recyclable. In 2026, we'll see the mandatory separated recycling and food waste in England. 2027, flexible plastics. We also have digital waste tracking, which is going to improve traceability, audit trails and stronger enforcement potential. So April 2026, we'll see the starts being rolled out for voluntary testing.
by waste receiving sites in the UK, which will lead to a mandatory rollout for waste receivers later in the year. So something for you guys to make sure that you are using legitimate and proper waste collectors, because this will be affecting you. And this is the key thing, hopefully once these two reforms are embedded,
This will help to keep EPR fees down by streamlining household collections and making governmental savings there and reducing illegal waste activities as well.
So packaging reporting, obviously, EPR has brought in huge upheaval across the packaging sector over the last couple of years, but that dust is finally settling. We've had two years of reporting under our belts and the first invoices or notice of liability sent to relevant producers. We've also got DRS. So work is underway by the UK Deposit Management Organisation.
now called Exchange for Change. So it is expected they're going to be moving on from the setup phase to the delivery phase, building, sorting centers, IT systems, setting up return points, labeling, testing, etc. ready for go live October next year, which is really exciting. And Exchange for Change are currently running a series of webinars in March on the regulations
business obligations and key timelines and Q&As. So please head over to the website and cheque those out if needed. And for plastic packaging tax, there'll be the usual rate increases, the yearly rate increases in April 2026. And this is going up to 228 pounds and 82p a ton. And an important aside as well,
Before I leave this slide, the UK emissions trading scheme is going to be expanded to the waste sector from 2028. While this sounds like some way off, this will eventually impact EPR disposal costs. So current estimates are that around 20 or 30% of weight of fossil materials sent to local authorities is incinerated, but it is in scope of EPR.
So once this material is in scope of ETS, we could see a marked increase in EPR base fees for some materials, especially flexible plastics, depending on the state of the UK infrastructure. So lots of things, lots of things going on, everything slowly falling into place, that lovely little puzzle.
So key takeaways. We can finally see the dust settling on packaging EPR reforms now that 2023 compliance year has been closed out. We have the first year of RAM reporting on the horizon at the end of month. So hopefully producers will be well on their way to gathering correct data and solidifying those supply chain communications. There are many reforms that are going to be affecting EPR base fees in the future.
including savings from harmonised waste collections and development of the RAM, who have indirect and direct effect on those EPR bases. And so I seem to be saying at the end of every presentation at the moment, data is still key if you want to keep on top of your costs, especially with evolving recyclability requirements and other eco-modulation factors. So the ability to react and make changes will
entirely depend on the accuracy of your data throughout your supply chain.
And a quick jump over the water to EU and what's going on in the world of packaging in the EU at the moment. So again, we have PPWR and a related national EPR reporting, which we'll come on to in a couple of slides. PPWR, of course, going to play this August. Amended by PPWR, we have the single use plastics directive, which is going to introduce further restrictions.
restricted packaging formats later in the decade. Also a planned review of the single use plastics directive for 2026 alongside work on recycled content, especially for pet drinks containers. There's a lot going on in that space at the moment. We also have ESPR and digital product passports. So while packaging won't be getting its own eco design requirements under ESPR in Europe, there are many pieces of information required.
by PPWR that will need to be linked to a QR code on packaging. And this should be linked then with the information for product passport requirements and other regulations. So rather than having a dozen different QR codes on your packaging, hopefully there'll just be one. And included in PPWR, but also covered by the Empowering Consumers Directive,
are rules and requirements around sustainability claims you can make about packaging or contained products which will come into force this year. So a lot to be mindful of there, especially when talking about recycled content and sustainability claims. And lastly, before I give you a break from all this heavy information, I'll hand you back over to Charlotte. There are a raft of other updates and goings on at the moment in the EU.
The main one to keep an eye out on for later this year is the Circular Economy Act. Again, waiting on another Circular Economy Act, where we could see further simplifications and harmonizations, not only across member states, but across different EPR regulations, which hopefully will be streamlining things such as reporting and registration requirements for producers, keeping those costs down.
reducing admin burdens. Thank you very much, Charlotte. Let me move back over to you.

Charlotte Davies   18:16
Thanks, Michael. A lot to keep in touch with, I think, there for EPR. It's a lot going on, but hopefully it is now starting to slow down a little bit. And then obviously we've just gone over those EU updates that are coming in. So lots to keep track of. But today we really wanted to focus on the packaging and packaging waste regulations.
since these are sort of one of the most impactful, I think, for most packaging producers or people placing products in packaging on the market at the moment. So what really are the aims of PPWR, I think, is the main question. So it replaces the existing directive, which was introduced in
2014. And there was some problems with this original directive in that each country was basically able to implement differently in how they wanted to. So it resulted in fragmentation of the regulations in each member state. So PPWR is a regulation which will hopefully enable minimum standards that will apply to the 27 member states. And so for you guys, things
should be getting a little bit simpler when you're selling into multiple EU countries. And I know definitely probably at the moment it doesn't feel like that when you look at the requirements, but hopefully it will sort of aim to standardise the existing EPR schemes and any that are rolling out.
So alongside that, we're looking to also harmonise the EU packaging requirements to support a single market. So in terms of recycled content, reusability, things like that, we're aiming to standardize, as well as setting standard rules for chemicals, sustainability, labeling, end of life management as well. So
It really is hopefully going to cut back packaging waste, reducing unnecessary packaging, boost the reuse and refill systems and increase recycled content and the recyclability of packaging. But alongside this, it also has an aim to protect human health by reducing those harmful substances.
So as a whole, basically enabling the circular economy and aligning with that waste hierarchy that we always want to keep to as we're going forward. And just a reminder, if you do have any questions, please do drop those in the chat or the Q&A area and then we can sort of go through those at the end. So we get a lot of questions about what
Who does PPWR apply to? So essentially, if you manufacture packaging or packaged goods that you're selling onto the EU market, you probably will have some requirements or obligations under it. If you're importing packaged goods into the UK, that's again another area of obligation. If you are
are supplying or distributing packaged or packaging into the EU market again. And it does also include e-commerce, so something to be considerate of if you're selling into the EU through online sales. It's also worthwhile highlighting, which a lot of people perhaps aren't aware of, that under the Windsor framework, elements of PPWR will also apply to Northern Ireland. So
Definitely, if you're selling into Northern Ireland, it's one to consider. However, it's worth recognising that not all requirements apply and there are some exemptions. So have a look at those. One of those is the reuse and refill obligations and some of the EPR reporting as well. Obviously, Ireland do their own thing with that. So make sure you have a look into
Northern Ireland, if you are placing packaged goods or packaging on the market there. Another question that we tend to get as well is what packaging is in scope of PPWR? And I know that we did a webinar at Bellamy and this was one of the main questions that came out. So I really wanted to address this today as well. So
Unlike in the UK with our packaging EPR where it's very much focusing on the new requirements around recyclability focus on that household element, PPWR does apply to all packaging and they do define it slightly differently and helpfully than we do in the UK with a sort of sales group transport category rather than primary, secondary and tertiary.
So just they're pretty much fall in the same definitions, but just to be aware of the group packaging can also contain grouping of certain sales units. So, you know, if you had a packet of crisps, a multi-pack would be classed in that grouped packaging. And obviously as well, the e-commerce focus as well this time. So definitely worth considering.
And there are some exemptions, so things like contact sensitive products, dangerous goods or heavy machinery and materials that perhaps aren't in those typical material ranges like cork, textiles, rubber. But please be aware that there isn't like a blanket exemption. So if you fall into any of those areas, you probably won't be exempt for everything. It might just be one or two of the requirements. So
Definitely something to consider as well.
Now, when we look at PPWR, I think one of the biggest challenges is its magnitude and the timeline and the number of changes that are happening over the next couple of years. So this isn't an exhaustive timeline, but we have tried to pick out some of the key elements that would likely impact food and drinks manufacturers like yourselves and really look at how that changes over the next sort of 10 years, really.
as we go through. So it's probably worthwhile noting some of the key areas that with the recycling criteria to be established by 2028 for implementation for 2030. We know as well that PPWR will apply from August of this year, so definitely there's some considerations there around address and ID labelling on packaging, as well as some of the substances
of concern like PFAS, which is coming in from August this year. And then you can see as well in August 2027, all member states must have set up their EPR reporting with producer registration due then. So that's again something if you're selling into a specific country, you need to make sure that you're signed up to the EPR scheme within there and submitting data.
And then something as well, which will hopefully bring sort of, I don't know, standardised labelling in terms of removing that confusion around sorting, which will come in in August 2028. So that's that EU wide harmonised labelling system, which we're really all hoping for.
whether it's going to be a bit more challenging to bring it in on packaging, that's another discussion, but definitely for a consumer sense, that is what we're looking for to help consumers manage where that waste goes at end of life. So we're going to try and go through, there are a lot of requirements, but we're going to try and touch on quite a few of these today in the session. First of all, focusing on the sustainability requirements. And as you can see there on the screen, there is quite a lot of them.
But we're going to quickly run through some of those key dates, key points, key considerations that you'll need as a producer over the next couple of years.
So to kick it off, we're going to focus on recyclability, which obviously under the UK EPR, we obviously already have this consideration. But this is split into two categories under PPWR, design for recycling and recyclability or recycled at scale. We're just going to look at design for recycling today because that's something that we've got
the most informational at this point, but yeah, definitely something to consider as well as recycling at scale. The 2 are kind of split. Design for recycling is how you design it. You know, you can make it as recyclable as possible, whereas recycling at scale is kind of considering actually in that member state, will that be recycled on that market or how they've got the infrastructure set up within that country.
So all packaging placed on the market in the EU will need to be recyclable by 2030, and there are some exemptions around those materials in terms of sort of woods, cork, textiles, and it's expected that modulation will still apply to those materials though. So although you might not have to grade them, they will probably still have a modulation.
And unlike RAM, where we have red, amber, green, they've decided to apply recyclability grades of letters, so A, B, C, and those will obviously feed into the modulated fees set up. The European Committee for Standardisation have been tasked with developing the standards for recyclability, which they are currently working on. And we're hoping to get
sort of this published as secondary legislation by 2028. So then you'll be able to finally look at that ahead of that 2030 deadline. And we know at the moment from the regulations that the parameters will be looked at for recyclability on the left hand side. So things like additives, adhesives, colours,
barriers and coatings, pretty similar to what we consider at the moment within RAM, but there might also be some other considerations as well on the right in terms of separability of components, available recycling technology, substances of concern, which again, something that probably most of you will have considered in terms of recyclability at some point.
But I think the key thing is, while we're waiting, there are already established recycling methodologies within the EU and there will hopefully be some alignment with RAM. So things like RECI class, there's also material recyclability methodology specific to materials. So things like C-Flex for flexibles. So as we're sort of coming towards those deadlines, it's really worthwhile.
sort of having a look at your packaging and reviewing them against those existing methodologies because they will be contributing into that final method that we'll see. So yeah, definitely something to be aware of and factor in.

Michael Jennings   27:55
Substances of concern. So these are on everyone's mind right now, especially with recycled content targets, which can compound the presence of certain SOCs. So these requirements kick off right away this August. We have concentration limits for certain metals you can see there on the screen.
PFAS limits of food contact packaging. So you can see those limits on the right side of the screen there. A couple of different ways of measuring this. So there's 20, 25 parts per billion for individual non-polymeric PFAS, 250 parts per billion for the sum of them.
And then we also have 50 parts per million for PFAS, which includes polymeric PFAS and some bits around fluoride measuring. So lots of technical things there. There is also the requirement to minimise the presence of substances of concern in packaging. And again, for proof of compliance, you need to evidence how you have minimised the presence of SOC in your technical
documentation. Test results may be needed for the concentration limits, so it's definitely worth talking through your supply chain as soon as possible to make sure you're able to gather this relevant information so you can evidence this in the necessary documentation. By the end of the year, the EU Commission should have prepared a report on any other
SOC for future measures and restrictions. But at the moment, we just have these ones on the screen. And outside of PPWR, we have Commission Regulation 2024 slash 3190, which will introduce a ban of BPA in food contact materials from July this year.
So definitely one to be aware of as well, especially if you're in the UK, because I know there's around PFAS and BPA, there's a lot of consultations going on around the status of that in the UK as well.

Charlotte Davies   29:53
I don't know about any of you guys, but I am not maybe as technical as my brain works and I just wanted to recap on what PFAS was. I know that was a focus for the webinar today and sort of what packaging we find it in. So it's really used for its grease and oil resistance, its thermal stability,
stick surfaces and sort of chemical resistances, which mean it can be commonly found in carbon, sorry, cardboard and paper packaging, but it's also in pretty much a lot of things because of its plastic lining. So often within bottles, there might be a plastic lining like a ketchup bottle, for example. So it's really worthwhile having a look if it might be within those packaging components. And you're probably already
be aware of that, but we just wanted to make sure that everybody knew sort of where you find it. And the reason it's such a challenge is because it really leads to sort of environmental and water contamination and it stays within the environment. It's one of those forever chemicals, so it's very hard to get rid of when it is in the environment. And there's also that
alongside is that human health sort of consideration as well. It can migrate into consumables, so the impact for us consuming those consumables. And then another big thing as well, when we look at the circular economy, it can hinder the recyclability of products, obviously with the water repellents and chemical resistance.
But also when we're looking at the output recycler, it's very hard to put stuff that has PFAS back into new packaging or new product. So it sort of limits the possibilities of that, which really rises that need for closed loop solutions. So yeah, just a little interlude for maybe if you're not a technical person to really understand behind the scenes of what PFAS is and what it does.

Michael Jennings   31:41
Thank you very much. So assessments for recycled content of plastic packaging don't kick in until 2029. And these will be based on a methodology that's due to be released hopefully by the end of this year, with the first recycled content requirements for different plastic packaging formats coming into force in 2020.
So first, we're going to have the methodology and the compliance with the methodology before hitting those targets, which is nice. And to note is the potential inclusion of bioplastic as part of the recycled content targets in the future, which the Commission will review around Q1 2028.
And you can see the targets up there on the right. Hopefully pretty attainable targets for 2030. The big jump up is 2024, when we could see some of these targets roughly double. So for single use plastic bottles, this jumps up from 30%
up to 65% recycled content. We could also see from 2029 when the recycled content methodology kicks in, we're going to see fee modulation based on the percentage of recycled content used. So lots of considerations here around food content packaging and hopefully as well,
The recycling landscape will be in a fair shape in 2030, 2035, 2040 to actually allow producers to meet these targets over the next three to five years.

Charlotte Davies   33:11
That's sometimes the challenge, isn't it? The cost of recycling is more expensive than the Virgin. So yeah, hopefully.

Michael Jennings   33:17
Yeah. And luckily there are bits and pieces in the legislation. So obviously the commission is going to review this over the coming years as this is implemented. And if there are issues with achieving these, if it's too expensive, if the technology is not right, then there will be adjustments made. So you're not just going to be left stranded in the cold.
and the Commission will be updating these as necessary. But like I say, hopefully, fingers crossed, it all will go to plan. And a bit further down the line for these areas as well. For those of you using compostable packaging, 2028 will be the requirement for certain packaging formats listed in the reg. So tea and coffee bags, fruit and vegetable sticky labels to be industrially compostable.
and for other compostable packaging not listed to have to be recyclable and not to contaminate other recycling streams. So that means either recyclable in a food waste recycling stream or conventional material recycling streams. And checking those dates on screen, we haven't heard anything as of yet regarding the compostable packaging standards.
which will obviously lead to clarification, development and innovation in this area. I think a lot of the secondary legislation is being pushed back and we're waiting on these. And on the packaging minimization side of things, there's going to be empty space limits for sales packaging in 2028. I know products such as crisps are caught up in this conversation at the moment.
with having that empty space, maybe not the same need in a plastic bottle. And this will be expanding out to the rest of packaging formats, a group to transport and e-commerce in 2030 with not only empty space requirements, but also produces needing to evidence packaging reduction to the minimum
Necessary to perform.
And for restricted packaging formats, I'm not going to talk through this entire slide, you can use it for future reference. Annex 5 on the left and the amendments to the single use plastics directive on the right, both layout restrictions of certain packaging types in the near future. I've just circled some on screen for the food and drinks industry and for Harika just to be aware of. So like,
As Charlotte said before, with the wording, we have that single use plastic grouped packaging. So this is not only for, say, secondary packaging that a business will get rid of, but this also includes multi-pack packaging as well. So this might be the end of multi-pack
crisp packets in a multi-pack plastic bag, because that external multi-pack bag will fall under that grouped packaging.
Kay.
And a quick highlight of general reuse, which on its own would take up a whole webinar before moving on to the reuse targets. From 2026, there are going to be rules and requirements about what is classified as reusable packaging, the role of reuse systems and requirements for those who operate them, and the obligations for businesses to offer refill.
So if you are using reusable packaging or have a system of consumer refill, it's really best to research these, get on top of these requirements, speak to the necessary people and make the necessary changes to your systems and operations as soon as possible so you don't get caught out on these. There's also going to be mandatory reuse and refill obligations for the hospitality and takeaway sector in 27 and 28 to be aware of, but again, not
to go through today, because that will take up a whole webinar. But moving on to reuse targets, which will affect everyone here. So starting in 2030, there's going to be a 40% reuse target for transport and e-commerce packaging. So including sales packaging used for transporting products, which will increase to 70%.
from 2024. This means that averaged out across all packaging formats, a percent of that packaging will need to be reusable and in a reuse system. You can't just say it's reusable and be done with it. That system of reuse has to be in place. So this is going to be pallets, boxes, IBCs, pails.
And also from 2030, there is going to be a 100% reuse obligation for all packaging for internal use. So transporting goods between your own sites or for transporting goods to another economic operator in the same member state. So this is the big one. And we have here, you can see on screen there, plastic wrapping and straps are now exempt.
from this 100% requirement, which is really nice, but not from the 40%, 70% averaged out target I mentioned before. Like I say, these, you've got some pictures on the screen there. These requirements are going to apply to pallets, boxes, trays, crates, IBCs, drums, and then a bit for pallet wrappings and straps, but will not include certain packaging formats, such as around dangerous goods.
flexible food contact packaging and custom design packaging for large machinery or commodities or cardboard boxes because cardboard boxes are very difficult to reuse. Other smaller reef targets, so grouped packaging, so this is for stock keeping and distribution, grouped packaging, again excluding cardboard boxes.
There'll be a 10% reusable target within a reuse system, increasing to 25% from 2040. And lastly, for final distributors to make alcoholic and non-alcoholic beverages in sales packaging, that's a bit of a mouthful, we'll need to ensure 10% are reusable within a reuse system, with a big jump up to 40% by 2040. So
For the food and drink industry, this is this, or for the drinks industry, this is a big one to be looking at over the next 5, 10, 15 years, but does exclude, amongst other things, milk and milk products, wine and alcohol-based spirits.
We're just waiting as well. Again, more secondary legislation from the Commission. They're hopefully going to establish a methodology for the calculation of reuse targets by June 2027, and producers are going to have to be able to demonstrate in their technical documentation achievement of these targets, which will be due around about June 2031, so six months within the end of a reporting year.
So lots to think about there on your transport and logistics arrangements.
So some things to think about on that, identify if you have or are using any reuse systems and make sure they meet the necessary requirements. Ensure they work to maintain the condition of packaging, including the ability to recondition packaging. Reuse systems can be operated by third parties, so see if there are existing schemes you can become a part of. And we're waiting for that secondary legislation
clarifications of in and out of scope packaging and methodologies to calculate those targets.
Labelling. So nearly at the most exciting news of the year so far, I think, and I think some people will be breathing a sigh of relief with some idea of direction of travel for labelling. First, some important information on labelling requirements that we will be reviewed from August 2026. And apologies for my terrible mock-up of some cardboard packaging there at the top of the screen.
So there's going to be two mandatory labelling requirements this year to packaging identification. So manufacturers must ensure that packaging bears a type batch or serial number or other element allowing its identification. Again, we're looking at traceability here. And then we have the company identification as well. So manufacturers
pictures and or importers must indicate on the packaging or via digital barcode their name, registered trademark or trade name, postal address, they can be contacted and any electronic means of communication. Again, this is all for traceability as well. There are some caveats as well where it's where
the importer or distributor is changes the packaging or the obligated people and micro enterprises. So please read the regulations sort of final for the final wording on caveats there.
The exciting bit, so we now have the Joint Research Centre's technical proposal for harmonised labelling across the EU. So here you can see a range of easily identifiable symbols and colours for packaging components. I know a lot of people are comparing this to Monopoly at the moment. And this is going to allow consumers
to easily place packaging in the bin with corresponding symbols. It would be a nice matching game. And it's worth noting, as I mentioned earlier, this will eventually feed into future mandatory labelling in the UK, as these labels will be mandatory in Northern Ireland from August 2028 as well.
So the paper that's been published is a hefty document. It's around about 247 pages. So I have gone through and just pulled out some of the main points for consideration and you can find some more information on our latest news story and in the technical documentation as well. So the symbols are largely based on the current Nordic labelling system and
Do denote material composition.
These will then match to the corresponding label on the bin top left. Some things to think about when you are designing packaging and information placement. If you are supplying packaging to multiple member states, you may have to think about what language or languages to use. I think someone's brought up Belgium recently that has three national languages.
that could be a potential lot of space on your packaging.
And as this is only a technical proposal, we'll have to wait on finalisation from the commission on things such as the labelling of specific packaging components. You can see there on the bottom left, we can see three potential examples. There's also going to be a mandatory digital barcode placement to think about too. And hopefully once all of this is thought about, there'll still be some space on your packaging for your brand.
We never know.
And a quick timeline of other labelling requirements. So from February 2027, there'll be the voluntary EPR scheme mark on the digital barcode to show that the producer has met their EPR obligations. August 2028, we're going to have the not to be discarded in nature label for compostable materials.
Where information on recycled content or bio-based plastic content is displayed, producers will have to use the relevant harmonised label included with that information, though this label wasn't included in the technical documentation. And there's also the mandatory labelling for DRS materials.
Moving up to 2029, again, going back to reusable packaging, reusable packaging must have a label informing users it is reusable with further information on that digital barcode. And it must be clearly identified and distinguished from single use packaging at point of sale. And then up to 2030,
packaging containing certain substances concerned shall have that information outlining the name and concentration again on the digital barcode. So it's going to be a lot on that digital barcode.
And general obligations. So unlike in the UK, where the obligation for packaging falls solely on the producer, for PPWR, it covers all actors in the supply chain from manufacturing import right through to distributors. So suppliers are going to need to provide manufacturers with information and necessary documentation.
for the manufacturers to complete their technical documentation and conformity assessments. Manufacturers must carry out those conformity assessments. Importers have to make that manufacturers have done the conformity assessments, packaging is labelled, there's relevant documentation, all the identifications are present. Distributors must verify that the necessary producer is correctly registered on the EPR register. Again, the
packaging is labeled. So a lot of things for each person in the time in the chain to think about. And there's also on the bottom right there, we've got information on the prevention and management of packaging waste. This currently does exist under the packaging directive. So producers or their PRO must make certain information available to consumers on their role in waste prevention, reuse, recycling, labeling,
etc. It is expected that member states and PROs will release further information on what producers specifically will need to do. So I know in a lot of cases, PROs and member states are already picking this up. So it is worth speaking to your PRO in advance of PPR coming into force just to make sure you're not missing anything and doing everything correctly there.
And I know I do keep talking about technical documentation and conformity assessment. So after you have made all of those changes and assessed all your packaging, doing running tests, making sure you meet the relevant requirements, you will need to put together this technical documentation which will evidence that fact and allow you to place your packaging on the market. This is the sole responsibility of the manufacturer who will ensure that the packaging satisfies the relevant requirements.
So we need to include at least the following. We have general description of the packaging and its intended use, conceptual designs, manufacturing drawings, materials of components, and descriptions and explanations for understanding those drawings and the operation of the packaging. There's going to be a list of harmonised standards and common specifications.
For example, when the design for recycling criteria or the recycle content methodology are published, how your packaging aligns with those standards or requirements, how you have come to your output, and then qualitative descriptions of assessments, recyclability, packaging, minimization, reusable criteria and relevant test reports.
Lots to think about and do. There's also going to be measures in place to ensure that manufacturing and monitoring stays compliant with the technical documentation. So this is all about getting up to speed with the requirements, evidencing that you're meeting those requirements and making sure you're not falling foul of them in the future.
And talking about reporting, I think I'll pass over to Charlotte now to run through relevant changes across the EU.

Charlotte Davies   47:31
Thanks, Michael. Yeah, I'll give you a break in talking. So I think it's worth mentioning as well, under all those other requirements that PPWR is setting out, that although there might be EPR already mandated in all EU member states, PPWR is not introducing packaging EPR from scratch, but it's aiming to harmonise, simplify and improve.
those systems. So some states will already have those EPR systems in place, but they'll have this PPWR regulation will obviously be setting out those minimum standards to meet those. So I think one key change that PPWR will bring is the establishment of a producer register in each member state to monitor producer compliance. And so within that, we're expecting annual reporting,
and that will probably mean for you guys that in terms of data reporting, there'll be some standardisation and packaging categorization, granularity, the same data reporting fields and validation rules. So that's definitely something to factor in as we're going forward through PPWR and when that will be brought in.
But ultimately, producers should see 2026 as the go live year, but use 2026 into 2027 as the period when the data specifications will be set in stone. So use this period to sort of build your systems that can support with sort of the national specific reporting for more detailed packaging.
reporting. So it's just worthwhile thinking that you might already be reporting to those EPR systems, but they might be changing to align, or sorry, they will be changing to align under those PPWR requirements. So definitely something to factor in. For small producers, they're also being redefined as producers placing less than 10 tonnes of packaging
into a member state. So the small producer status is defined at national level and not that total EU wide tonnage. That's definitely something to bear in mind. And I think PPWR explicitly links market availability to registration status. With the introduction of national registers, that producer compliance status is expected to be hard control in the supply chain.
chain. So basically, in short, producers without that registration in place and not visible will obviously be blocked from placing goods on the respective markets. So perhaps with the EPR system in the UK, there's a little bit more leeway in terms of who's compliant, but definitely for the EU, that registration is key to be able to sell into those member states.
So before we finish up for questions, we just wanted to cover a few of the key takeaways. And I think from my perspective, we've got all this stuff going on and Michael's given some great analysis of what's to come. But I think getting prepared and horizon scanning is key in the terms of looking at your design. And I always try and get this statement onto any webinar that I do, that 80% of a product's environmental impact is
is predetermined in the design phase. So the design of packaging is crucial in terms of how it will be impacted by these regulations by both UKPR and PPWR. So that's definitely thinking about packaging reduction, lightweighting, and we've definitely seen that on the market at the moment in the UK. I had a sushi
a product the other day and it was incredibly lightweight, the PET tray and lid. When we're looking at that recyclability, make sure you're considering the existing collection systems, but also existing methodologies because they will be used to guide what will come. And then another massive one is that reuse or refill. So really looking at
I know sometimes it's quite difficult to factor that into business practices, but thinking, okay, maybe it's easier to implement this for transport packaging, there will be requirements coming in for that. So let's focus on that first and then potentially longer term looking at the sort of sales level reuse or refill systems.
But obviously we all have to consider this with the actual function that packaging plays and the product is that key thing that we need to protect with the packaging. So yeah, it's a hard one to balance, but by thinking all these things and looking into the design from the beginning, you will definitely be benefited when all these different requirements are being rolled out later on.
So we just wanted to sort of have some key bullet point takeaways and I think we've gone through everything in quite a lot of detail, so definitely something to come back and digest. But some key things for PPWR and this year's compliance, we've obviously got that substance of consent restrictions coming in from August of this year, focusing on PFAS as well.
And definitely in terms of those ID and reporting labelling that will be on packaging that Michael covered as well with his cardboard example. And then I think when you look more long term into the future considerations, Michael said it as well, that data is key. Unless you can sort of evidence and support what you've done to change and meet these requirements, you won't be able to achieve compliance.
sure that you've got that future-proof packaging data systems in place. How can you store this data? How can you report this data? Really looking into that as a priority. And I think when we're looking at the labelling as well, we know it's coming. We know it probably takes about two years to get that label onto packaging. So looking at how you can
enable those transition plans, looking at the timelines from the EU and how we can sort of place those onto packaging as soon as we can. But I'll stop there because I'm conscious we've got some Q&As coming up. But yeah, I'll hand over to Ealanor.

Ellena Andrews   53:16
Thank you both. This has been really informative, actually, and I hope for members online, you know, it's turned what can feel like a bit of a minefield of regulation into some much clearer stepping stones. So we've got a good few questions. So one of them
and it's something that as FDF we see sort of time and time is around the labelling requirements and whether they are going to apply to placed on the market in Northern Ireland and timelines. Are you able to sort of highlight anything on that?

Michael Jennings   53:52
Yeah, so Northern Ireland for labelling is entirely aligned with Europe. So if everything goes to plan, we're going to see those harmonised labels apply in, or is it August 2028 for Europe and Northern Ireland, I could say hopefully,
The UK government, now we have this technical documentation, the UK government will be jumping on board this, not waiting for the commission to do their final piece. So we know direction for the rest of the UK as well. Because ideally we want alignment to stop those barriers there. And I know a lot of people have talked about this as well in the Q&A. I've probably left it on the slide. So it's
It's a Q&A topic. It's totally on purpose. The labelling will not apply to transport packaging. So it'll apply to the sales packaging, grouped packaging, both types of grouped packaging that is for consumers and for businesses to get rid of, and also e-commerce packaging, but it will not apply to
Transport, so you don't be sticking it on pallet wrap.

Ellena Andrews   54:57
Thank you. Hopefully that answers the question.
So, and I think that answers, we've had a few questions around how PPWR interacts with the UK EPR and I think that is one of the main sort of contention points on that is the interaction with Northern Ireland.
Another question we've had from members is, with plastic packaging intended for direct food contact, can it contain recycled content? And if so, what is the regulation for it?

Michael Jennings   55:34
So yeah, so to recycle content targets, there are specific ones for, let me get it up on my screen. So I think some of the targets are 30% recycled content for contact sensitive PET, excluding beverage bottle.
bottles and 10% recycled content for contact sensitive, not PET, excluding beverage bottles, and then 30% for beverage bottles. So those recycled targets are there for food contact packaging. I can say hopefully this all goes to plan. If there are any issues with supplying costs, I'm sure the EU Commission will step in.
But it's also worth, obviously, with the increase of recycled content in your packaging, you've got to look more closely at substances concerned. And I think we'll see more closed loop systems coming into place for those as well.

Charlotte Davies   56:26
They do also list some exemptions for that recycled content, so it's worthwhile seeing if some of the products fall into those. And I think looking this morning, they do have a food contact sensitivity exemption, but you have to be able to evidence it, I think, in an approved manner.
So it might be worth looking into that. And I know some formula, so baby formula is also exempt from some of those. So although the requirements are slightly lower for food contact sensitive, there are some exemptions in that. So it might just be worthwhile nailing down whether your product would fall into those.

Ellena Andrews   57:08
Perfect. Thank you both. I've got 2 minutes left, so I will do one final question, if that's all right. And I think
Well, as we've got 2 minutes, it's the, you know...
To finish, what is the sort of, how should food and drink producers prepare for the new harmonised recyclability labelling requirements under PPWR? What is your?
Key stepping stones.

Charlotte Davies   57:36
So I would say the first thing you need to do, because obviously we've got the draught out and Michael's sort of talked through that and we know it probably will apply to Northern Ireland and probably will apply to the UK if all goes swimmingly. What you want to do is really make sure that you've got that data on all your packaging. So you'll have
that material and subcategory information is crucial. So making sure that you have that for everything. And definitely if you've been meeting the UK RAM requirements, you should have some insight on that already. So that's perfect. And then the next step really for me would be making sure that you've got those labelling and graphic reviews lined up.
before we know that the regulations come in. So giving yourself ample time to sit there and make sure that you've got the space potentially for these labels to be put on. And again, that consultation that's out at the moment will give you a little bit more of an understanding of the size or scale or what you'd need to apply. But really making sure that you've got that in your plan so that when it does get confirmed, it's not suddenly a massive rush to get them implemented.

Ellena Andrews   58:25
Yeah.

Charlotte Davies   58:40
actually you've already got that in your planning timeline of graphics or packaging formats so that you know you've got the data and you've also got it lined up as something that you've got to come before the regs is confirmed almost. That would be sort of my approach. I don't know, Michael, if you've got anything to add to that.

Michael Jennings   58:57
No, that's why I would say this is it is a technical proposal from the JRC. So it has technical information in there. It has sizes, fonts, shapes, spacings. It's got everything in there. So pull up your pull up your packaging designs, you take your and work out where you can put these. Is it going to be black and white? Is it going to be see-through? Is it going to be colour? Are they going to be languages? And they're not going to be languages. Where's it going to be placed?
Go through all of these things as soon as possible. So when the final stats are released, you can jump straight in and make those changes rather than being delayed further.