UK’s FPA urges evidence-based packaging reform as US$36B sector faces overlapping EPR, DRS, plastic tax compliance burdens

UK – The Foodservice Packaging Association has called on the UK Government to ensure packaging policy reforms are workable, evidence-based and fair to businesses, warning that overlapping measures including EPR, DRS and plastic packaging tax risk undermining investment and compliance without delivering environmental results.

In a letter to Environment Minister Emma Hardy MP, the FPA warned that reforms would only succeed if they were workable, based on evidence, fair to businesses and able to deliver environmental results. 

The association represents 130 manufacturers and distributors with a combined economic footprint of more than £27 billion (US$36.3 billion) and 70,000 jobs. 

It stressed that packaging used in foodservice is part of the system that allows food and drink to be supplied safely across multiple sectors.

Five Priority Areas for Early Action

The FPA’s letter outlined five areas requiring immediate attention. 

On extended producer responsibility, the association called for a review of producer registration and enforcement, greater clarity on how fees are calculated, and stronger checks to ensure that all obligated businesses are paying. 

It also requested that recyclability fee modulation be delayed until confidence in the system has been established. 

The UK’s pEPR scheme saw £1.4 billion invested in its first year, with fees to be modulated based on a red-amber-green recyclability rating from 2026/27.

The FPA also pressed for policy coherence, noting that plastic packaging tax, while overseen by HMRC rather than Defra, adds to the same compliance burden. 

The tax applies at £223.69 per tonne to plastic packaging with less than 30% recycled content. 

The association urged ministers to consider how these policies interact, so they do not overlap unnecessarily or undermine investment decisions.

Investment Certainty and Evidence-Based Policy

The letter called for clear timetables, stable guidance and confidence that collection, sorting and reprocessing capacity would be available. 

It referred to the delay to mandatory collections of plastic films and flexibles, as well as upcoming changes linked to pEPR, RAM, DRS and Plastic Packaging Tax. 

The FPA urged the government to support domestic manufacturing and avoid putting compliant UK producers at a disadvantage as costs rise. 

The association emphasised that future environmental rules should rely on life cycle evidence and whole system impacts rather than assumptions about particular materials. 

The FPA said it backed producer responsibility in principle but wanted reform to proceed in a way that protects consumers from avoidable costs, supports manufacturing and gives companies enough certainty to invest.

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