IN Brief:
- Around 89% of obligated producers continue to use some packaging outside the green recyclability rating.
- Approximately three-quarters report a mixture of red, amber, and green-rated formats.
- Food packaging redesign remains constrained by barrier performance, shelf life, line compatibility, material supply, and validation requirements.
BagKraft has analysed UK extended producer responsibility data indicating that 89% of obligated packaging producers continue to place some red, amber, or otherwise non-green packaging on the market.
Approximately three-quarters of the businesses covered use a mixture of red, amber, and green-rated formats, while only around 10% report using green-rated packaging exclusively. A smaller group continues to rely entirely on material within the weakest recyclability category.
The figures reflect the complexity of packaging portfolios used across food, beverage, retail, and other consumer markets. A single producer may manage hundreds of specifications combining films, trays, bottles, cartons, labels, adhesives, closures, coatings, and secondary packaging.
Extended producer responsibility transfers more of the cost of managing household packaging waste to the businesses placing packaging on the UK market. Charges initially reflect material type and weight, with recyclability modulation applying higher or lower fees according to performance under the Recyclability Assessment Methodology.
Food packaging that receives a weak rating is often performing a necessary technical function. Multilayer structures can provide oxygen, moisture, aroma, grease, or light barriers that maintain safety and shelf life, while closures and seals must withstand filling, transport, retail handling, and storage.
Removing one layer or changing polymer chemistry can alter seal strength, puncture resistance, rigidity, print quality, transparency, and machine behaviour. A nominally recyclable structure that causes leaks, reduced shelf life, or higher line waste can create a different set of environmental and commercial losses.
Calls for greater regulatory stability across European packaging policy have intensified as producers manage EPR, recycled-content targets, the Packaging and Packaging Waste Regulation, and national implementation requirements simultaneously.
Recyclability reaches the production line
The 89% figure does not mean that most producers have made no progress. A business using one difficult component alongside many recyclable formats remains within the non-green majority, although the result shows how difficult it is to remove every problematic specification.
Pack redesign begins with material development but quickly becomes a production engineering project. A new web, tray, closure, label, or coating must run through forming, filling, sealing, cutting, coding, inspection, case packing, and palletising without reducing output or increasing rejects.
Changes in friction, stiffness, thickness, static, curl, heat response, or dimensional tolerance can force adjustments to web tension, sealing temperature, dwell time, guides, tooling, and line speed. Equipment installed for an older structure may have a narrower operating window than the replacement material requires.
Product validation then extends beyond the trial itself. Migration, shelf-life, microbiological, transport, drop, compression, and storage testing may be needed before a specification can change, while retailers and brand teams must approve artwork, appearance, and customer-facing claims.
Material availability can delay progress even after a format is technically approved. Demand for mono-material films, recyclable barriers, food-grade recycled polymer, fibre formats, and compatible coatings can rise faster than suppliers are able to commission capacity.
Manufacturers operating through co-packers face a further constraint because a replacement must work across several lines and sites. A material that performs well in one factory may fail on older sealing equipment or a different forming system elsewhere in the network.
EPR also exposes weaknesses in packaging data. Material composition, weight, market destination, and recyclability rating may sit across separate procurement, technical, finance, design, and supplier systems. Incorrect master data can produce inaccurate liabilities even when the physical packaging has changed.
Finance teams are consequently becoming more involved in decisions previously led by packaging development and marketing. The lowest purchase price no longer represents the complete cost when producer fees, line efficiency, waste, transport, and shelf life are included.
A staged approach allows high-volume, poorly rated packs to be addressed first. These formats can justify more substantial tooling, material, and validation expenditure, whereas low-volume specialist structures may remain difficult to replace until commercially viable alternatives emerge.
Fee modulation can encourage redesign only when ratings remain aligned with collection, sorting, and recycling capacity. A pack developed for a theoretical recycling route still requires household participation, suitable infrastructure, and stable end markets before its material value is recovered.
Most producers have introduced some packaging that performs well under the rating system, yet comparatively few have eliminated every weaker format. The next phase will be measured through specifications changed, machinery validated, reliable data submitted, and fees reduced across real production portfolios.
