PackUK and the UK Packaging PRO have set out a revised approach to updating the Recyclability Assessment Methodology (RAM), giving the industry a more active role in shaping future changes.

The UK Packaging PRO will work with stakeholders throughout the packaging value chain to identify areas for improvement and prioritise proposed amendments, drawing on evidence and industry feedback.

PackUK will continue to oversee and publish the methodology, although further responsibilities are expected to pass to the PRO following RAM 2028.

The revised approach responds to feedback from producers and other stakeholders seeking a clearer timetable for changes, alongside more opportunity to assess their implications and prepare for implementation.

Jeremy Blake, Chief Executive Officer at PackUK, said: “This is a valuable opportunity for PackUK and the UK Packaging PRO to work together, combining our expertise and shared purpose to make meaningful improvements shaped by stakeholder feedback from across the packaging value chain.

“By introducing this dedicated route for producers to engage with and contribute to the RAM, we are giving industry a stronger voice in guiding future developments and ensuring a broad range of insight is reflected in how the methodology evolves.”

The UK Packaging PRO will be responsible for collecting, reviewing and ranking proposals from stakeholders under the revised process. Producers will have access to a formal route for submitting change requests, helping ensure practical industry experience and technical knowledge inform the methodology’s development.

For the 2028 update, PackUK and the PRO intend to concentrate on a more limited set of priority issues. These will include areas previously raised by producers, such as guidance relating to take-back schemes.

The aim is to make future revisions more focused and predictable, while retaining the flexibility to respond to new evidence and feedback from stakeholders as they emerge.

Karen Graley, Chief Operating Officer at UK Packaging PRO, added: “We know how important the RAM is to producers, and this process provides a real opportunity to bring industry expertise and practical experience into its future development.

“I’d encourage producers of all sizes to get involved. We want to hear what is working well, where improvements are needed and what the evidence tells us.”

Stakeholders wishing to put forward proposals for RAM 2028 must submit their supporting evidence to the UK Packaging PRO by 31 December 2026.

The PRO will review each submission to establish whether it provides sufficient grounds for a potential change. It may also approach submitters to request further evidence, clarify details or discuss proposals in greater depth.

Submissions that present a strong case for additional investigation will undergo further assessment, with the PRO using the findings to help formulate recommendations for PackUK.

Five waste management companies have been selected to deliver logistics and processing services for the UK’s forthcoming Deposit Return Scheme (DRS).

The appointments follow a tender process, with contracts allocated across different regions of the UK. Three nations have confirmed who has been awarded contracts, with the exception of Wales, which is yet to be decided.

The DRS is due to launch in October 2027 across England, Scotland, Wales and Northern Ireland. Exchange for Change is the Deposit Management Organisation (DMO) overseeing the scheme’s implementation across all four nations.

Russell Davies, Chief Executive of Exchange for Change, said: “The Deposit Return Scheme will transform how the UK recycles. This is not only about preventing waste from polluting our towns, countryside, rivers and beaches, but also about investing for the long term in new environmental infrastructure, jobs and opportunities across the UK.

“Together the five waste management companies will create a resilient and scalable collections network that will ensure efficient collection and processing of DRS materials.”

Exchange for Change said the initial infrastructure is expected to be operational from October 2027. This will comprise three dedicated DRS processing facilities in Scotland, Scunthorpe and Guildford, alongside two dedicated processing lines at Isle of Dogs and Newry. A shared-use plastics recycling facility in Avonmouth will also support the scheme.

A further phase of infrastructure development is planned for October 2030, when three purpose-built facilities are expected to open in Ely, Cambridgeshire; Knowsley, Merseyside; and Avonmouth.

The rollout will also involve the deployment of approximately 400 new recycling vehicles to collect eligible containers across the UK.

The scheme will cover single-use drinks containers with a volume of between 150ml and three litres, made from PET plastic, steel or aluminium.

A refundable deposit of 20p will be added to the purchase price of eligible drinks. Consumers will be able to recover the deposit by returning their empty containers to designated collection points.

The Environment Agency has extended its Regulatory Position Statement (RPS) 330, delaying certain packaging Extended Producer Responsibility (EPR) data collection and reporting requirements until 2028 and 2029.

The updated RPS 330, published on 25 August, extends the regulatory position to cover data for 2026 and 2027.

Under the position, the Environment Agency will not normally take enforcement action where producers fail to collect and report certain data relating to packaging EPR.

This applies to data covering the period from 2024 to 2027.

The Environment Agency said the delay would reduce the regulatory burden associated with data collection and reporting requirements, which do not affect producer disposal fees or recycling obligations for producers, compliance schemes and holding companies.

RPS 330

The updated RPS delays the introduction of several data collection and reporting requirements.

Self-managed organisational waste data collection is delayed until 1 January 2028, with reporting required on or before 1 October 2028.

Nation of Sale data collection is also delayed until 1 January 2028, with reporting required on or before 1 April 2029.

Meanwhile, data collection for plastic and paper bags is delayed until 1 January 2028, with reporting required on or before 1 April 2029.

The Environment Agency said the reporting requirements remain part of the Packaging Regulations. However, where the conditions are met, producers will not normally face enforcement action for failing to collect or report the specified data.

The RPS does not affect any other legal requirements under the Packaging Regulations.

The Environment Agency will review RPS 330 by 31 December 2028.

A trial is underway in Belgium to test whether digital watermarks can improve the sorting of flexible food packaging and help increase the availability of recycled material for food-grade applications.

The trial will examine how invisible digital watermarks can be used to identify characteristics of packaging, including its material type and whether it has previously been used for food.

As part of the project, sorted bales of flexible film collected through Belgium’s household recycling system will be analysed using specialist sorting equipment.

The material will be sent to Hündgen Entsorgungs’ sorting centre in Germany, where high-resolution cameras supplied by machine manufacturer Pellenc ST will scan the packaging and detect Digimarc digital watermarks.

The watermarks are imperceptible codes applied across the surface of packaging during the printing process. Their use is being investigated as a way of creating more targeted sorting streams, particularly for flexible food packaging, which can be difficult to recycle into high-quality applications.

The trial is being led by Fost Plus, the organisation responsible for packaging waste recycling and reuse in Belgium, and forms part of the HolyGrail 2030 – Circular Packaging Consortium.

The consortium is facilitated by AIM – European Brands Association and brings together around 79 companies and organisations, including brands, technology providers, packaging converters, sorting companies, recyclers and research institutes.

Mondelez International, PepsiCo and pladis are among the companies participating in the trial.

Richard Akkermans, European R&D Packaging Productivity and Sustainability Manager at Mondelēz International, said: “HolyGrail 2030 is a pivotal, cross-industry initiative for better sorting and recycling of flexible packaging in the EU.

“Achieving circularity for food-contact flexible plastics isn’t just an ambition, it’s a necessity.

“In order to be ready for the ambitious recycled content targets in the upcoming EU Packaging and Packaging Waste Regulation, this market demonstration aims to provide the real-life technical learning that the value chain needs in order to increase the availability, compatibility and affordability of recycled plastic coming from new technologies.”

Food-grade Recycling

The ability to produce high-quality recycled material from flexible food packaging remains challenging, with accurate identification and sorting among the issues facing the sector.

Digital watermarking could potentially help separate packaging according to characteristics that are difficult to identify through conventional sorting methods.

However, sorting is only one part of the process required to produce food-grade recycled material, which also requires suitable recycling and decontamination processes.

Liz Morrish, CEFLEX Leadership Team – Operations Director, said: “Food-contact recycled content is where the industry has some of the biggest challenges and the least time.

“This trial moves testing from evidence-gathering into commercial reality, which is exactly what bridging the gap between ambition and the 2030 targets requires.”

The trial comes as the European Packaging and Packaging Waste Regulation (PPWR) introduces new recycled content requirements for certain plastic food packaging from 2030.

The requirements include a minimum of 10% recycled content for some contact-sensitive packaging applications, increasing the focus on technologies that could improve the supply of suitable recycled plastics.

Drinks producers will not pay a producer fee during the first 15 months of the UK Deposit Return Scheme (DRS), under fee rates announced by Exchange For Change.

The industry-led organisation responsible for delivering the UK-wide scheme has confirmed that the producer fee will be set at zero pence per container when the DRS launches in October 2027.

The 0p rate will remain in place until the end of December 2028, with fees then expected to be introduced from January 2029.

Exchange For Change said the initial zero-fee period would help limit costs for businesses as the scheme gets underway.

Russell Davies, Chief Executive of Exchange For Change, said: “We recognise the breadth of work being undertaken by industry to prepare for launch in October 2027. Setting a 0p producer fee for the first 15 months of the scheme is intended to support businesses in the early stages of the scheme."

“As a not-for-profit organisation, we are committed to ensuring that producer fees always remain as low as possible, while supporting the long-term financial sustainability of the scheme.”

What is the producer fee?

Producer fees are intended to contribute towards the cost of running the DRS.

Based on current projections, the fee is expected to rise to 0.6p per aluminium and steel container and 2.3p per PET container from January 2029. These rates are currently forecast to remain in place until December 2032.

Exchange For Change stressed that the figures are not final, with the proposed fees due to be reviewed and validated in May 2027, ahead of the DRS launch.

The fees will also be subject to annual reviews once the scheme is operational, with changes possible as more information becomes available on costs, contracts and the performance of the system.

Exchange For Change said it had developed the proposed fee structure following consultation with businesses across the drinks supply chain.

Responses were received from producers and retailers of varying sizes, with the organisation saying the feedback had helped shape both the proposed rates and the approach to setting them.

The announcement follows confirmation from Exchange For Change that a flat 20p deposit will apply to all drinks containers covered by the scheme.

Consumers will pay the deposit when purchasing an in-scope container and receive the full 20p back when the empty container is returned.

Businesses intending to use chemically recycled plastic to meet Plastic Packaging Tax (PPT) recycled content requirements have been given greater clarity following the publication of new guidance from HMRC.

The updated guidance confirms how a mass balance approach (MBA) can be used to account for chemically recycled plastic content in plastic packaging for PPT purposes from 1 April 2027. The new framework introduces certification, record-keeping and audit requirements that organisations across the supply chain will need to meet if they wish to attribute chemically recycled content towards the 30% recycled content threshold.

HMRC guidance can be found via the following links:

• Preparing to use a mass balance approach for Plastic Packaging Tax
• Minimum certification requirements for a mass balance approach for Plastic Packaging Tax

What Has HMRC Announced?

HMRC has confirmed that any business using a mass balance approach to demonstrate recycled content from chemically recycled plastics must do so through a third-party approved certification scheme that meets HMRC's minimum requirements. The requirements apply throughout the supply chain, with all relevant businesses expected to hold the appropriate certification. Importers of finished plastic packaging will also need evidence that their suppliers are certified under a compliant scheme.

The guidance is designed to provide a consistent and auditable method for tracking chemically recycled material through complex manufacturing processes where physical segregation of recycled and virgin feedstocks may not always be possible. While chemically recycled content can be attributed to packaging using a mass balance system, businesses will be required to maintain robust controls and clear documentation to support any claims

Key Requirements for Businesses

Under the new rules, businesses using a mass balance approach will be required to:

• Operate a site-level mass balance system with a three-month accounting period.
• Ensure no negative mass balance occurs at any point.
• Apply site-specific conversion factors during processing.
• Use the fuel-excluded attribution method where outputs include fuel-use products.
• Maintain valid certification and supporting documentation.
• Retain attribution declarations and mass balance records for at least six years.
• Obtain a new attribution declaration each time material changes ownership within the supply chain.
• Undergo certification audits conducted by accredited certification bodies under approved schemes.

What is a Site-Level Mass Balance System?

A key aspect of HMRC's approach is the requirement for a site-level mass balance system. This means that recycled material entering a manufacturing site must be tracked and matched against the recycled content attributed to products leaving that same site, rather than being balanced across multiple facilities within a wider business.

To demonstrate compliance, operators will need detailed records covering:

• Quantities of chemically recycled material received.
• Processing losses and conversion factors used.
• Quantities of recycled content attributed to finished products.
• Opening and closing stock levels.
• Inputs and outputs of both recycled and virgin materials.

Who is Affected?

The guidance will only affect businesses that intend to use a mass balance approach for chemically recycled plastic when calculating recycled content for Plastic Packaging Tax purposes from April 2027. Companies that rely solely on mechanically recycled plastic will not be impacted by these requirements.

Manufacturers, converters, packaging producers and importers should now review their current systems and supply chain arrangements to assess whether additional certification, documentation or process controls will be required ahead of implementation.

Looking Ahead

The publication of these requirements marks an important step in HMRC's efforts to establish a recognised framework for chemically recycled plastics within the Plastic Packaging Tax regime. Businesses planning to utilise chemically recycled feedstocks should begin preparing now, ensuring that their mass balance systems, record-keeping processes and certification arrangements align with the new requirements ahead of the April 2027 implementation date.

For further information, HMRC has published guidance on preparing to use a mass balance approach and the minimum certification requirements that certification schemes must meet.

Local authorities are being encouraged to register for the government’s Digital Waste Tracking (DWT) service as preparations continue for mandatory reporting in October 2026. This follows the legislation being passed by government earlier this year.

Defra has opened registration to councils that operate, manage or have responsibility for waste sites, giving them the opportunity to establish their accounts ahead of the first mandatory requirements.

The first phase of Digital Waste Tracking is scheduled to become mandatory in October 2026 in England and Wales, followed by Scotland and Northern Ireland in January 2027.

The requirements will vary between the four nations.

In England, waste received at permitted sites will generally need to be recorded, although household waste deposited by residents at permitted household waste recycling centres (HWRCs) is excluded.

For local authorities, the current scope in England is limited to sites handling commercial waste. HWRCs in Wales, Scotland and Northern Ireland are expected to enter the system during later phases.

Preparing for DWT

Defra is recommending that local authorities register before the mandatory reporting requirements begin.

Early access will allow councils to establish their “Report receipt of waste” service account, allocate users and permissions, and agree reporting arrangements for sites operated by contractors.

It will also give staff time to become familiar with the platform and prepare for submitting information once reporting becomes compulsory.

Councils are being advised to assess their reporting responsibilities across their sites and contractors and decide how they will submit information.

Available options are expected to include direct submission through an API for operators using compatible waste management software, as well as a spreadsheet-based route.

Defra has also stressed that existing waste recording requirements will continue to apply during the transition to DWT.

Local authorities that took part in the private beta will need to complete registration again before the system becomes mandatory.