Year one of EPR has set the baseline, and the invoices are coming
PACKUK's Chief Strategy Officer Esther Carter set out where extended producer responsibility stands after its first full year. The scheme has funded almost £1.5 billion into local authority collection and sorting, with more than 4,000 producers now inside it. In practice, the calendar matters most: producers must submit all 2025 data and corrections by 1 September 2026, after which PACKUK calculates fees without recalculation.
PACKUK derives fees by dividing local authority net costs by total tonnage placed on the market. Carter admitted that reconciling a constantly shifting dataset has been one of year one's hardest problems, and the regulator is now adjusting the rules to carry surpluses and deficits between years.
Takeaway: the quality of what you report (tonnages, material classifications, format data) directly shapes what you pay. Under-resourced data processes are now a line-item risk.
Recyclability is now priced into every pack
The most consequential development for producers is how the Recyclability Assessment Methodology (RAM) now attaches a cost to design. Red, amber and green ratings are no longer reporting labels: they're a fee multiplier.
Modulation sits at 20% this year, meaning red-rated material costs 20% more than amber. That climbs to 60% next year and 100% by year three, when a red pack costs twice as much as an amber one. Early summit data showed roughly one in seven producers currently placing only red-rated packaging, with around 10% fully green.
Carter's headline scenario made the stakes concrete: around 20% of UK packaging is currently rated red, incompatible with today's recycling systems. Remove that material and UK household recycling could rise from 64% to the mid-80s. The newly released RAM 2027 raises the bar again, judging recyclability not just on what's collected but on what's genuinely sorted, reprocessed and sold into viable end markets.
Takeaway: a format can no longer claim recyclability on the strength of its material alone. It has to survive the real-world recovery chain, and knowing where your portfolio sits against the RAM is now core to managing cost.
"Better" has to be proven, not assumed
Several sessions circled the same question: how do you know an alternative is actually better? A panel featuring Mondelez's Richard Ackermann, Recoup's Richard Chen and WRAP's Adam Herriot examined the risk of regrettable substitutions: swapping plastic for paper or fibre formats that solve one problem while worsening another, whether in carbon, food waste or end-of-life recyclability.
The shared conclusion: "better" only holds up when lifecycle data proves it, not when a press release asserts it. Canopy's Kate Green made the case for alternative fibres backed by certification such as RSB, while Smurfit Westrock set out the discipline of fibre circularity and the waste hierarchy, where reduction and reuse come before recycling.
Takeaway: substitutions producers can't defend with lifecycle evidence carry both reputational and regulatory exposure.
Reuse and refill need a business case that survives contact with reality
Reuse is the part of the hierarchy most brands endorse and fewest have operationalised at scale. Lowell Ryan's panel, with voices from ReUse, Touch and Suez, examined what it actually takes to make refill and return commercially viable: standardised formats, workable return logistics, and consumer behaviour that holds up beyond a pilot.
Reuse models only work when unit economics, logistics and customer experience align, and that alignment remains the exception, not the rule. A related infrastructure panel drew out a parallel gap on the recycling side: the mismatch between what brands ask consumers to recycle and what facilities can actually process, with flexibles the sharpest example.
Takeaway: design with the realities of collection and reprocessing capacity in mind, not an idealised version of it.
Net zero claims are only as good as the data behind them
Sonia Sánchez's net zero panel, with WRAP, the Metal Packaging Manufacturers Association and Benchmark, grounded the sustainability conversation in carbon accounting. The recurring tension was ambition versus rigour: Scope 3 emissions and lifecycle assessments only steer decisions when the underlying data is credible. Standards such as ISO 14067 offer the guardrail against claims that don't survive scrutiny.
Lord Deben (John Gummer) closed the day by setting the reforms in historical context. His throughline matched the summit's: sound decisions need sound evidence, and the smart move is to adapt with clarity rather than relitigate the rules.
The common thread: everything came back to data
Step back from the individual sessions and one subject ran through all of them, not as a topic but as the precondition for every other one. Every lever the summit discussed (EPR fees, RAM ratings, material substitutions, reuse business cases, net zero claims) now runs on data, and the quality of each decision is capped by the quality of the underlying dataset.
Yet the data most producers hold thins out at exactly the point it matters most. Reported figures at the point of placing on market are relatively robust; understanding of what actually happens to that packaging downstream is far patchier. The recurring frustration across panels was less about willingness and more about visibility: teams are asked to defend decisions on stretches of the value chain they can barely see.
What this means for packaging teams
If Sustainability & Impact 2026 had a single message for producers, it's that packaging decisions are now judged on evidence, and the financial consequences arrive fast. Fees track recyclability ratings. Lifecycle data assesses material switches. Public targets invite scrutiny. Each depends on knowing, not assuming, how a pack performs, from the spec sheet through to what happens to it after a consumer is done with it.
That end-of-life picture is where most packaging teams still lack visibility. A format designed to be recyclable, reusable or low-carbon only delivers if it behaves that way in the real recovery system, and producers have historically had the least visibility at exactly the point where packaging travels furthest down the chain. As RAM modulation sharpens the cost of getting it wrong, closing that gap between design intent and real-world outcome becomes a competitive advantage. Producers who can show, with data, how their packaging performs will be best placed to manage fees, defend their sustainability commitments and stay ahead of where the regulations are heading.
That's precisely the gap Deepnest closes. Deepnest turns real-world recovery data, drawn from Greyparrot's global network of Analyzer units, into packaging waste intelligence: evidence of how a pack actually performs once it leaves the shelf, not just how a lab test predicts it will. For packaging teams building that evidence base, that's where the proof starts.
Deepnest by Greyparrot helps brands, retailers and packaging producers design more circular products with packaging waste intelligence. Learn more.