The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (the 2024 regulations) currently define fibre-based composite (FBC) material any “packaging material which is made of paperboard or paper fibres, with a layer of plastic, and which may also have layers of other materials, to form a single unit that cannot be separated by hand”.
However, the definition of fibre-based composite in PackUK’s ‘Recyclability Assessment Methodology (RAM)’ – applicable to Household data reporting in 2025 – draws a distinction between such materials, depending on the plastic content, i.e.,
- Fibre-based composite packaging with plastic content less than or equal to 5% by weight should be assessed as Paper and Board.
- Fibre-based composite packaging with plastic content greater than 5% by weight should be assessed as Fibre-Based Composite.
To resolve the potential contradictions in reporting, Defra plans to amend the 2024 regulations, including definitions for FBC and Paper and Board that align with those included in the RAM.
These amendments are planned to come into force on 1st January 2026.
Whilst this will naturally allow H2 2025 (July-December) reporting of FBC and Paper and Board that conforms to the new definitions, H1 2025 reporting (January to June) – following the definitions in the unamended 2024 regulations – would remain contradictory.
To provide a temporary solution, the Regulators have issued Regulatory Position Statement 351 (RPS 351).
RPS 351 allows producers to apply the RAM definitions of FBC and paper/board when reporting their 2025 packaging data, even though the official regulations will not align until 1st January 2026.
This means producers can choose to apply the new definitions when assessing and reporting their packaging data, rather than adhering to the current definition.
The RPS also allows for the resubmission of H1 2025 packaging data if producers need to align with the new definitions.
Andrew McKale, Senior Account Manager at The Wastepack Group said “We welcome the revised definition of fibre-based composite packaging, which brings greater alignment with the RAM. This change not only gives clarity and consistency of definitions for producers, but it also offers potential cost savings through reduced Local Authority waste disposal fees for packaging that was previously classed as 'Fibre-Based Composite' but which can now be reported as 'Paper and Board'.
View our previous RAM PackUK story here - "RAM for EPR Updated by PackUK [07.05.25]"
