Since January 2025, packaging extended producer responsibility (pEPR) has been live in the UK, and producers have been paying the full cost of managing the household packaging they put on the market. A deposit return scheme is due in 2027. Simpler Recycling is rolling out across households and businesses. Digital waste tracking, the Circular Economy Growth Plan and, for anyone trading into Northern Ireland or the EU, the Packaging and Packaging Waste Regulation (PPWR) are all moving from consultation into consequence. The decisions producers make over the next 24 months will be made against a regulatory backdrop that is finally settling into place.
That shift was the whole story at Biffa's fifth Waste Net Zero summit in July. A phrase surfaced repeatedly across the day, borrowed from a senior official and picked up by CEO Michael Topham and the closing remarks: "it's not perfect, but it's happening." It's a fair summary of a sector that has spent years talking about ambition and is now, visibly, in delivery.
Here is what the day surfaced, and why it matters for brands and the wider value chain.
The economics of packaging design have changed
Defra's Clare Delaney, Portfolio Director for the Circular Economy, set out the policy architecture with unusual candour. The principle behind pEPR is simple: the cost of managing packaging waste now falls on the producers who create it. The mechanism that makes it bite is modulation. Fees are tied to how recyclable a piece of packaging is, assessed through the Recyclability Assessment Methodology (RAM). Difficult or expensive-to-recycle formats cost more; well-designed, recoverable ones cost less.
That reframes packaging design as a line on the P&L. In its first full year, the scheme is channelling around £1.4 billion annually to local authorities to fund recycling services.
The other levers are lining up alongside it. The deposit return scheme launches in 2027 with a 20p deposit on PET, aluminium and steel drinks containers and a target collection rate of around 90%. Delaney pointed to the Republic of Ireland, which launched in February 2024 and has already collected 2.5 billion containers, cut related litter by 55% and lifted the recycling rate on those containers from 49% to 90%. Simpler Recycling is standardising what households and businesses can recycle and will extend to micro-firms in 2027.
Takeaway for 2026: none of these levers works in isolation, and none works without visibility into what actually happens to material at end of life. Data and design are now the same conversation.
What producers are telling each other
Coca-Cola Europacific Partners' Jo Padwick described a labelless "naked" Sprite bottle trial run with Tesco across ten stores. Without a prompt, shoppers assumed it was a mistake or plain water and reached for something familiar instead. The lesson for brands attempting more radical packaging changes is that recognition happens in about three seconds at the shelf, so communicating a genuine sustainability improvement without eroding brand identity is its own design problem.
Esterform's Duncan Oakes, whose ESTErPET reprocessing (turning recovered plastic back into raw material for new packaging) feeds recycled PET back into bottles, raised a structural risk familiar to any producer with a cross-border supply chain: keeping valuable recovered material in the UK once an export restriction closes off a working loop. Two related themes recurred through the day: interoperability across the four UK nations, and the reach of EU rules such as PPWR into GB businesses that ship to Northern Ireland or export into Europe, a market the Food and Drink Federation values at £25.6 billion.
Who pays, and what "good" is measured against
Müller's David Tonkin voiced a concern several producers share: are these reforms building a better circular economy, or simply a more expensive waste collection service? His position was that producers should pay, but that pEPR must be judged on outcomes and behaviour change, not the volume of money collected, and that funding needs to reward genuine circularity, where material goes back into itself rather than being downcycled into lower-value uses.
Suffolk County Council's Steve Palfrey grounded it in numbers: his authority receives just under £40 per household in pEPR against roughly £150 per household spent on waste services, with the scheme now covering about a quarter of that cost. UK Packaging PRO's Cat Hay named a recurring frustration from a decade representing producers: policies were designed in isolation rather than as a system, and consumer behaviour remains the hardest variable to control.
The room largely converged on two points. The "ring-fencing" debate over pEPR money was described by several panellists as a red herring, since the funding covers the real, existing cost of handling packaging; the more useful conversation is transparency over where it's invested. And the biggest near-term driver of design change may not be a UK rule at all, but PPWR, because producers optimise their portfolios for the largest market they serve.
The visibility gap is now a brand problem
If one theme connected the whole day, it was that you cannot manage what you cannot see. Manual sampling covers a vanishing fraction of the material flowing through the system, which means most decisions about packaging recyclability have been, in effect, educated guesses.
This is the gap Deepnest, Greyparrot's packaging waste intelligence platform, is built to close. Greyparrot CEO Mikela Druckman set out how: waste-specific AI applied to material moving across sorting lines, recognising more than a hundred categories in real time, with a fleet spanning 250 Analyzer units across 20 countries, tracking billions of objects. What began in 2019 as a Biffa request to measure inbound composition has matured into commercial infrastructure and, recently, a regulatory milestone: the Environment Agency has accepted AI-generated data in place of manual sampling for compliance reporting, with Biffa and FCC leading the way.
For brands, the more pointed development is what that visibility reveals about sortability, the proportion of packaging that actually gets sorted into the correct material stream at recovery facilities, as opposed to what's simply designed to be technically recyclable. Druckman's data shows cartons recovered at under 5% in the UK against roughly 90% in Spain; in categories such as cosmetics, packaging barely enters the recycling stream at all. Through SKU-level recognition, that gap between design intent and recycling reality is becoming measurable, and therefore actionable: better consumer education, redesign, or a shift to reuse.
Others reinforced that data is only half the job. Reath's Emily Rogers demonstrated a tool, built with Biffa, that pulls packaging data into one place and automates RAM ratings and EPR submissions, showing producers the financial and legislative impact of a material change before they make it. GoUnpackaged's Catherine Conway shared national reuse modelling, run with Tesco, Ocado and Biffa, showing that curbside reuse systems can come in cost-comparable to or cheaper than single-use, with EPR fee savings of up to 94% because a reusable pack is only charged the first time it enters the market.
Takeaways for packaging teams
End-of-life performance is no longer a reporting afterthought. Under modulated pEPR and an evidence-based compliance regime, it is a cost, a compliance obligation and a design input. Three things follow from that:
- The fee model rewards proof, not intent. Modulated pEPR and RAM scoring mean sortability, not theoretical recyclability, determines what a format costs to bring to market.
- PPWR is the design constraint to watch. Producers optimise for their largest market, so EU rules will shape UK packaging decisions as much as domestic ones.
- The data gap is closing, and that cuts both ways. Real-world, SKU-level recovery data makes it possible to prove sustainability claims to regulators and consumers, but it also makes it possible for others to see where those claims don't hold up.
The brands that close the gap between what they believe happens to their packaging and what measurably does, and that treat reduction and reuse as the first options rather than only recyclability, will be the ones setting the pace the rest of the value chain organises around.
Get in touch to find out how your packaging performs in global waste streams.