IN Brief:
- PackUK’s second-year EPR framework introduces modulated disposal fees for 2026 to 2027, with red-rated formats carrying a 20% uplift on amber fees.
- Flexible plastics, fibre-based composites, and other hard-to-recycle formats are under renewed scrutiny as RAM reporting starts to influence packaging cost directly.
- Packaging review cycles are likely to tighten as producers balance recyclability, food protection, technical performance, and audit readiness.
Food Nutrition Partners has warned food manufacturers that the next phase of packaging extended producer responsibility is moving from guidance into direct cost exposure, as PackUK prepares to apply eco-modulated disposal fees from the 2026 to 2027 scheme year. For producers already reporting under the reformed rules, the change turns packaging recyclability from a compliance line into a live commercial variable.
The structure is built around the Recyclability Assessment Methodology, or RAM, which rates in-scope packaging red, amber, or green. Amber remains the reference point, while red-rated formats attract a higher disposal fee and green-rated formats receive a discount. That shifts attention onto materials that have long been tolerated on performance grounds but are harder to process within existing recycling systems, particularly some flexible plastics, fibre-based composites, and complex layered structures.
For food businesses, that creates a narrower design brief than a simple material swap. Barrier performance, shelf-life stability, sealing behaviour, migration compliance, pack weight, print finish, and line efficiency still need to hold. A more recyclable format that undermines product protection or processing reliability will not solve the problem for long, which is why technical teams are likely to be pulled much earlier into packaging cost reviews.
Connor Sharkey, regulatory and specifications manager at Food Nutrition Partners, said businesses should prepare on the basis that scrutiny will intensify as the reporting regime matures. His advice is blunt: “Act as if you are going to be audited.”
That points to a second pressure beyond the fee itself — evidence. RAM ratings are self-reported, but the system relies on documentation that can withstand regulatory challenge. Supplier declarations, recyclability assessments, pack specifications, and any design-change records will matter more where companies are trying to justify a lower-fee outcome or defend an assessment for a technically complex pack.
Illustrative year-two fees already show how material categories are beginning to separate. Paper and board remains relatively low compared with plastic and fibre-based composite materials, while the modulation model will widen the difference within each material family depending on rating. That does not mean every paper-based alternative will be cheaper in practice, because converting, barrier coatings, and line changes can quickly offset headline fee gains, but it does mean the old assumption that compliance and pack economics can be reviewed separately is breaking down.
Manufacturers that have not already mapped their household packaging portfolio against RAM criteria are running short of time. The most immediate route is a full material audit, backed by supplier evidence and a review of which formats can be simplified without compromising food safety or product quality. Current guidance and RAM requirements are available on GOV.UK, but the operational reality is straightforward enough: packaging that is harder to recycle is becoming more expensive to keep.
