# Flexible plastic is the format brands are furthest from making recyclable, and most EPR tables already charge it a premium

> Flexible plastic packaging trails rigid by a wide margin on recyclability (Unilever reports 75% of its rigid plastic packaging but 15% of its flexible plastic packaging as reusable, recyclable or compostable in 2025), and in 8 of the 12 fee tables SPI compared, a PE or general film line costs more per tonne than the nearest rigid line of the same scheme.

Publisher: Strategic Packaging Insights  
Published: 2026-10-14  
Last updated: 2026-10-14  
Page: https://www.strategicpackaginginsights.com/insights/flexible-packaging-recyclability-gap/

**Flexible plastic packaging trails rigid by a wide margin on recyclability (Unilever reports 75% of its rigid plastic packaging but 15% of its flexible plastic packaging as reusable, recyclable or compostable in 2025), and in 8 of the 12 fee tables SPI compared, a PE or general film line costs more per tonne than the nearest rigid line of the same scheme.**

Strategic Packaging Insights (SPI) set Unilever's and ITC's reported rigid and flexible splits against the film and rigid fee lines in the SPI EPR & Plastic Tax Calculator and the EU's staged recyclability rule ([PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)). The result is a format problem with two price tags: an EPR premium already paid in several markets and widening in some, and a design test that applies in the EU from 1 January 2030 at the earliest.

## Executive summary

Flexible packaging (films, pouches, sachets, wrappers and laminates) is where the packaging industry's recyclability gap now sits. Unilever, the one company in the SPI Buyers Database that reports recyclability separately by format, puts 75% of its rigid plastic packaging and 15% of its flexible plastic packaging in the reusable, recyclable or compostable bracket for 2025. ITC reports a similar split on recycled content: 35.5% in rigid packaging and 4.5% in flexible packaging for FY 2025-26.

The EPR fee tables price that gap. In 8 of the 12 schemes SPI compared, a tonne of PE or general film costs more than the nearest rigid line in the same scheme, from 1.08 times in the Netherlands to 4.78 times in Oregon. The premium is moving: it widened in Spain, British Columbia and Ireland for 2026, and Fost Plus has already set a 17.7% rise in its PE film rate for 2027.

SPI sorts the schemes into four pricing types, and the type decides which lever cuts a brand's bill. Where acceptance lists set the price (Oregon, Colorado, British Columbia), getting film collected matters most. Where format sets it (Spain, Luxembourg, Belgium), the polymer and construction matter. Where recyclability ratings set it (the UK and, through discounts, the Netherlands), design evidence matters, and the spread is growing: the UK multiplier on red-rated packaging rises from 1.2 to 2.0 by 2028-29.

The EU rule turns the cost question into a market-access one. All packaging placed on the EU market must be recyclable, with the design-for-recycling test applying from 1 January 2030 or 24 months after the criteria are adopted, whichever is later. Packaging below grade C will be treated as non-recyclable. Unilever's flexibles target, 2035, lands five years after that earliest date.

The scenarios in this piece show the size of the money. On 1,000 tonnes of household plastic in the UK, a red rating would cost GBP 545,000 in year 2 against GBP 415,000 for green, and on SPI's arithmetic about GBP 910,000 in 2028-29 if amber holds at today's illustrative level. Leaders should report recyclability by format, rank every flexible SKU by fee line and likely grade now, and plan redesigns to the EU date rather than to later corporate target years.

## Key findings

1. Unilever reports that 57% of its plastic packaging was reusable, recyclable or compostable in 2025: 75% of rigids (76% in 2024) and 15% of flexibles (13% in 2024), against 100% targets for 2030 (rigids) and 2035 (flexibles) (Unilever Annual Report and Accounts 2025, p. 30).
2. **SPI analysis:**  if Unilever's 57% is the weighted result of its two formats on the same basis, flexibles are about 30% of its plastic packaging but about 59% of the part that is not yet reusable, recyclable or compostable.
3. In 8 of 12 fee tables compared, the PE or general film line is dearer than the nearest rigid line in the same scheme, from 1.08 times in the Netherlands to 4.78 times in Oregon; for France's PE lines, Ireland, Portugal and the UK it is the same rate (SPI calculator rows, consulted 12 to 14 October 2026).
4. The premium widened for 2026 in Spain (4.05 to 4.36 times HDPE), British Columbia (3.65 to 3.91, after film and laminates rose 26.0%) and Ireland, where non-recycled plastic went from 3.14 to 3.72 times recycled rigid plastic (SPI fee market analysis, 14 October 2026).
5. Under [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/), Article 6(1) has applied since 12 August 2026; the design-for-recycling test applies from 1 January 2030 or 24 months after the Article 6(4) delegated acts, due by 1 January 2028, whichever is later; below grade C is non-recyclable, and the floor rises to grade B from 1 January 2038 (Commission Notice C/2026/3084; recital 28).
6. The UK multiplies the base fee for red-rated packaging by 1.2 in 2026-27, 1.6 in 2027-28 and 2.0 in 2028-29; in the December 2025 illustrative data, 21% of RAM-rated packaging was red ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/), PackUK).
7. The SPI Buyers Database holds 41 recyclability targets among 148 live targets, and Unilever is the one company in it that reports a rigid and flexible recyclability split (SPI Buyers Database, 14 October 2026).

## Why flexible packaging is the hard case

Flexible packaging does a lot with very little material. That is its strength and, at end of life, its problem. Thin, light, often multi-layer and often contaminated with food, it is harder to collect, sort and recycle at scale than a bottle or tub. Fee tables and recyclability rules both respond to that, in different ways.

This piece reads the problem through three SPI datasets. The SPI Buyers Database holds 41 recyclability targets set by brand owners and retailers, with their latest reported progress. The SPI EPR & Plastic Tax Calculator holds 216 published fee rows in 14 markets, many with separate film or flexible lines, and SPI's fee market analysis of 14 October 2026 adds the 2025 and 2027 tables where schemes publish them. The SPI Regulation Tracker holds the PPWR recyclability rule ([PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)), the UK's fee modulation ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)) and the US and Canadian laws that set 2032 recyclability and recovery dates.

## The 60-point gap: Unilever's rigid and flexible split

Unilever is the one company in the SPI Buyers Database that reports its recyclability result separately for rigid and flexible plastic packaging. Its Annual Report and Accounts 2025 gives the overall result and the two sub-rows in its non-financial performance table.

Three things in Exhibit 2 matter. The gap between formats is 60 points in 2025. Rigids slipped by one point and flexibles gained two between 2024 and 2025, so the overall figure held at 57%. And the company has named its next route.

> "will increase our focus on transitioning to paper-based flexible packaging"

***Unilever** , company, Annual Report and Accounts 2025, Sustainability Review p. 29, March 2026*

The sentence refers to the period from 2026, and it explains why paper-based flexibles get their own section below.

SPI analysis

The overall result lets us estimate the format mix. If 57% is the weighted average of 75% and 15% on the same basis, rigids are (57 - 15) / (75 - 15) = 70% of the total and flexibles 30%; the 2024 figures give the same split ((57 - 13) / (76 - 13) = 69.8%). On that reading, of the 43% of plastic packaging that is not yet reusable, recyclable or compostable, flexibles account for 30% x 85% = 25.5 points and rigids for 70% x 25% = 17.5 points. Unilever does not publish the split, so this is an estimate, and the basis (weight or another unit) is the company's.

**SPI calculation**  At the 2024 to 2025 pace of 2 points a year, Unilever's flexible figure would reach 35% by 2035. At half that pace it would reach 25%. Reaching 100% from 15% in ten years requires 8.5 points a year, more than four times the pace just reported. The target therefore depends on a change in what collection and sorting systems accept as recyclable flexible packaging, or on a move to other formats such as paper-based flexibles, rather than on steady incremental progress.

## The same split in recycled content

The rigid and flexible gap is not unique to one company or one metric. ITC, which is both a packaging buyer and, through its Paperboards, Paper and Packaging business, a packaging maker, reports recycled plastic by format.

In practice: ITC Limited.

ITC placed 73,762 tonnes of plastic packaging in FY 2025-26 and reports 35.5% recycled plastic in rigids and 4.5% in flexibles, against 2030 goals of 60% and 20% "where permitted" by food and drug rules (ITC ESG Fact Book FY 2025-26). It has moved some Bingo large packs to recyclable polyolefin laminates, Fiama handwash pouches to mono-material and Mangaldeep packs to a 100% mono-material laminate, and its BioSeal coating replaces multi-layer plastics in quick-service tubs, tea envelopes and sugar sachets (SPI Buyers Database profile). SPI calculates that the flexible goal needs about 3.9 points a year from FY 2025-26 to 2030. The company reports its 3.22% overall recycled content on a different page and does not reconcile it with the format figures.

SPI analysis

Exhibit 4 shows the format gap on two different measures in two different companies. On recycled content, ITC's rigid figure clears India's 2025-26 Category I level and its flexible figure does not reach the Category II level. A company that reports only a blended figure gives buyers, regulators and investors no way to see which side of that line each format sits on.

## Flexible against rigid in each fee table

EPR fees are where the recyclability gap starts to cost money. Exhibit 5 pairs, inside each scheme, a film or flexible line with the nearest rigid line in the same polymer family, in the scheme's own currency.

Laminates go further. Fost Plus's code 014-03 (other plastics including aluminium laminates and PVC) is EUR 4,419 per tonne, 12.3 times its clear PET bottle line; Citeo's complex or other resins line (6.6.2) is EUR 1,400.1, 2.0 times its clear PET bottle; Oregon's laminates line is USD 2,248.72, 4.1 times its clear PET bottle (calculator rows). In Ireland the test is whether the material is recycled, not its format: non-recycled plastic pays EUR 616.22 per tonne against EUR 165.70 for recycled rigid or flexible plastic, 3.7 times more (Repak 2026 fee sheet).

**SPI calculation**  Take 10 tonnes of mono-PE film placed on each market, priced at the scheme's film line and at its matching rigid line, in each scheme's own currency. Rows are not to be added or compared across currencies.

| Scheme | Film: 10 t | Same tonnage at the rigid line | Premium for film |
| --- | --- | --- | --- |
| Oregon (USD) | 9,479.90 | 1,984.20 | 7,495.70 |
| Colorado (USD) | 10,582.20 | 3,086.50 | 7,495.70 |
| British Columbia (CAD) | 18,400 | 4,700 | 13,700 |
| Spain (EUR) | 12,430 | 2,850 | 9,580 |
| Luxembourg (EUR) | 7,120 | 3,058 | 4,062 |
| Belgium (EUR) | 10,804 | 8,019 | 2,785 |
| Netherlands (EUR) | 13,200 | 12,200 | 1,000 |
| France (EUR) | 7,701 | 7,701 | 0 |

The Oregon and Colorado premiums happen to be the same amount, USD 7,495.70, because both states' film-to-bottle gaps are 34.0 US cents per lb (43.0 against 9.0 in Oregon, 48.0 against 14.0 in Colorado). The comparison is per tonne; a rigid pack usually weighs more than the film it replaces, so the real saving from a format switch is smaller and depends on the pack. SPI has not modelled pack weights.

## Four ways fee tables price flexibles

The pattern in Exhibits 1 and 5 is not random. Each scheme prices film through one main mechanism, and SPI groups the twelve into four types. The type tells a brand which lever moves its bill.

SPI analysis

In acceptance-priced schemes, moving a film from "not collected" to a collected list is worth more than any polymer change inside the same list: in Oregon, PE film on the PRO list at USD 947.99 per tonne against PP film, not accepted, at USD 2,248.72 is a 58% saving on that line. In the near-flat and rating-priced schemes the format itself carries no premium, but the design of the pack does, through bonuses in the Netherlands and France and through the red multiplier in the UK. A single global flexible packaging strategy will therefore pay off unevenly: collection work in North America, polymer and construction choices in Spain and Belgium, design evidence in the UK and the Netherlands.

## The premium is moving

Fee tables are reset every year, and the 2026 and 2027 tables show the film premium widening in several schemes.

The reasons differ by scheme. In Spain the film line fell 1.9% for 2026, from EUR 1,267 to EUR 1,243 per tonne, but HDPE fell faster, from EUR 313 to EUR 285; the 2027 table moves film to EUR 1,269 and HDPE to EUR 282 (Ecoembes 2025, 2026 and 2027 tables). In Ireland the gap between recycled and non-recycled plastic widened from EUR 304.04 to EUR 450.52 a tonne as Repak's board aligned fees with the real cost of each material. In Belgium, Fost Plus's 2027 table raises PE films by 17.7% to EUR 1.2721 per kg and rigid PP by 12.3% to EUR 1.1409 per kg (Fost Plus rates page).

British Columbia gives the plainest reason. Its 2026 schedule shows film and laminates rising from CAD 1.46 to CAD 1.84 per kg, against HDPE bottles from CAD 0.40 to CAD 0.47.

> "Plastic Film and Plastic Laminates have significant variances on account of Step 4 investments."

***Recycle BC** , stewardship agency, 2026 Fee Schedule, October 2025*

The context is that acceptance-priced schemes charge film for the cost of building the collection it lacks, so the premium can rise while that investment is made, before any recycling result shows up in the rate.

## Paper-based flexibles: a lower line, not always a low one

Moving from plastic film to paper is one route out of the film lines, and Unilever names it for 2026. Fee tables treat paper with a plastic coating or laminate as its own category, priced above plain paper.

In Oregon, polycoated paperboard (USD 1,058.22 per tonne, not on either list) is above PE film on the PRO list (USD 947.99). In Colorado, where polycoated paperboard is on the AML at USD 440.92, it is well below PE film at USD 1,058.22. Italy's CONAI paper bands run from EUR 45 for single-material paper with at least 95% fibre (Band 1) to EUR 285 for type D composites below 60% paper (Band 6), with certified composites priced below non-certified ones (CONAI, consulted 14 October 2026). Spain penalises paper and board composites with less than 85% fibre, and British Columbia's paper laminates rose from CAD 0.62 to CAD 0.77 per kg for 2026.

SPI analysis

A paper-based flexible is cheapest where the scheme treats it as paper and dearest where it is classed as a composite that is not collected. The fee case for a switch therefore has to be made market by market and construction by construction, with the barrier layer and its share of weight checked against each scheme's category rules, including the fibre thresholds that Italy and Spain set at 95%, 60% and 85%.

In practice: Mars.

Mars is testing both routes at once. It launched a mono-material polypropylene WHISKAS wet pet food pouch, designed to be recyclable, in the UK and Germany, with a 46% lower packaging carbon footprint, and has launched paper wrappers for KIND bars (Mars releases of 31 July 2025 and 1 May 2025, in the SPI Buyers Database profile). Mars reported 67.6% of its plastic packaging as recyclable, reusable or compostable in 2025 against a 100% goal for that year. On the fee tables in this piece, the PP pouch would sit on a PP film line where one exists, which in Belgium costs 2.05 times PE film, while a paper wrapper's line depends on its fibre share.

## The UK: the rating sets the price

The UK has one plastic rate per recyclability rating rather than separate film lines, so a flexible pack's cost depends on its RAM rating. PackUK's modulation statement sets out the aim.

> "to incentivise producers to use packaging that is more environmentally sustainable."

***PackUK** , scheme administrator, producer disposal fees modulation statement, dated 28 June 2025, published on GOV.UK 17 February 2026*

The statement makes the mechanism budget neutral: only red packaging is uplifted, and the extra money funds an equal percentage discount on every green tonne, while amber pays the base fee. In December 2025, 71% of RAM-rated packaging was green, 8% amber and 21% red, but only 45% of first-half 2025 tonnage carried a rating, so PackUK calls its figures illustrative and likely to change significantly ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)).

**SPI calculation**  In year 2 the red rate of GBP 545 per tonne on 1,000 tonnes is GBP 545,000, against GBP 415,000 for green, a spread of GBP 130,000. With amber held at GBP 455, the red rate becomes 455 x 1.6 = GBP 728 in 2027-28 and 455 x 2.0 = GBP 910 in 2028-29, so the same red tonnage would cost GBP 910,000. A flexible pack rated red that is not redesigned would therefore roughly double its UK disposal fee in two years, before any change in council costs.

SPI analysis

Red rates also fund the green discount, so the more red tonnage producers report, the larger the discount for everyone else. For a brand with many red-rated flexibles, the mechanism moves money from its own bill to its competitors' green packs. PackUK expects to calculate confirmed year 2 fees in November 2026, with the notice of liability by the end of that month.

## The Netherlands: discounts that reward design

Verpact sets near-equal plastic rates, EUR 1,320 per tonne for flexible and EUR 1,220 for rigid in 2026, and then takes money off for design. A flexible pack of at least 90% PE or PP earns EUR 0.10 per kg off; so do natural, colourless or white colour, labels and print within limits, and a "goed recyclebaar" (good recyclable) rating in the current year's KIDV Recyclecheck. Post-consumer recycled content of at least 10% (contact-sensitive) or 20% (other) earns EUR 0.20 per kg. The combined discount cannot exceed EUR 0.60 per kg (Verpact Regeling Tariefdifferentiatie Plastic 2026).

**SPI calculation**  EUR 1,320 minus four EUR 100 design discounts is EUR 920 per tonne; adding the EUR 200 recycled-content discount reaches the EUR 600 cap and EUR 720 per tonne, 45% below the base. On 100 tonnes of flexible packaging, that is EUR 132,000 against EUR 72,000.

SPI analysis

The Dutch table shows that a flexible format is not penalised as such; a poorly designed one is. The same design work that earns the Dutch discounts (mono-material, light colours, limited print, a recyclability rating) is the work that the PPWR's design-for-recycling grades and the UK's RAM rating are likely to reward, so one redesign can pay in three systems, though each needs its own assessment.

## PPWR: the staged recyclability rule

[PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/) is where flexible packaging stops being a cost question and becomes a market-access one. The Commission states the aim plainly.

> "Make all packaging on the EU market recyclable in an economically viable way by 2030."

***European Commission** , DG Environment, Packaging waste page, consulted 14 October 2026*

The legal timetable is staged. According to the Commission's guidance, Notice C/2026/3084 of 10 June 2026, Article 6(1), "All packaging placed on the market shall be recyclable", has applied since 12 August 2026. The measurable test for design for material recycling, Article 6(2)(a), applies from 1 January 2030 or 24 months after the Article 6(4) delegated acts enter into force, whichever is later; those acts are due by 1 January 2028. The test for collection, sorting and recycling at scale, Article 6(2)(b), applies from 1 January 2035, or for the at-scale element five years after the Article 6(5) implementing acts. Until the design test applies, manufacturers keep meeting the essential requirements carried over from Directive 94/62/EC, with standards such as EN 13430:2004 (SPI rule analysis, 14 October 2026).

The recitals explain the grades:

- formats are assessed against design-for-recycling criteria and expressed as performance grades A, B or C (recital 28);
- packaging below grade C is treated as technically non-recyclable (recital 28);
- from 2035 the assessment also covers whether packaging is recycled at scale (recital 31);
- from 1 January 2038 the minimum is grade B (recital 28);
- the grades are linked to the modulation of EPR fees (recital 35).

The percentage thresholds behind grades A, B and C sit in Annex II, which SPI has not yet confirmed against the official text, so none is stated here. Some packaging is out of scope, including packaging for infant formula and packaging used to transport dangerous goods, and lightweight wood, cork, textile, rubber, ceramic, porcelain or wax sales packaging; exemption from the recyclability rule does not remove the duty to pay EPR fees (recital 34).

SPI analysis

For flexible packaging the PPWR makes the problem binary once the design test applies. A film that falls below grade C cannot stay on the EU market, whatever fee it pays. Unilever's flexibles target year, 2035, is five years after the earliest application date, so any flexible format on the EU market that is not recyclable by then has to be redesigned or removed earlier than the company's own target implies. Because the date moves with the delegated acts, the practical planning date is set by their publication: if they enter into force on 1 January 2028, the test applies on 1 January 2030; if later, 24 months after.

In practice: Haleon.

Haleon names its own hard case: high-barrier sachets such as Theraflu, for which it says no commercially viable recycle-ready solution exists yet, alongside blister packs. It has nearly finished moving toothpaste tubes from aluminium-barrier laminates to mono-material HDPE and says it will revisit its 2030 recyclability goal in 2026 to align with the PPWR (Haleon Annual Report and Form 20-F 2025, in the SPI Buyers Database profile). Some over-the-counter medicine packaging may fall under the PPWR's contact-sensitive or medicinal provisions; SPI has not checked which.

Outside the EU, the same direction is set by different tools. Minnesota requires covered materials to be refillable, reusable, recyclable or compostable with a collection system from 1 January 2032, with extensions possible to 2040 ([PR-US-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-006/), MPCA). California's SB 54 requires all covered packaging to be recyclable or compostable by 1 January 2032 ([PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/)). California's SB 343 limits recyclability claims and the chasing-arrows symbol to items that meet its criteria, such as collection by programmes serving at least 60% of the population, for items manufactured after 4 October 2026; a federal court enjoined enforcement on 14 July 2026, and the tracker status is being updated in the 13 October check ([PR-US-011](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-011/)). Ontario's Blue Box sets flexible plastic recovery at 10% for the best-efforts years 2026 and 2027, 15% from 2028 and 25% in 2032 ([PR-CA-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/canada/pr-ca-003/)).

## Where brand owners stand on recyclability

The SPI Buyers Database records 41 recyclability targets, each with the company's own latest figure. Scopes differ: some cover all packaging, some only plastic, some only own-brand items, and some are "by design" rather than as collected and recycled. Compare each company with its own target, not with the others.

Reading across Exhibit 12, the results cluster in two bands. Companies whose portfolios are mostly bottles, cans and glass report figures in the high 90s, such as HEINEKEN at 98% and Diageo at 99%. Retailers with broad own-brand plastic ranges report much lower figures, such as Ahold Delhaize at 33% (2024) and Target at 41% for owned brand plastic packaging (2025), with Carrefour at 67.2% for Carrefour-brand packaging (2025). Nestlé India, whose packaging is mostly flexible plastic for noodles, coffee, confectionery and dairy powders, reports 59% designed for recycling in 2024 against the group's 89.5% in 2025 (SPI Buyers Database, 14 October 2026).

SPI analysis

The companies near 100% are largely those with few flexibles, and the low results come from broad food and household ranges where film, pouches and wrappers are common. Only Unilever reports the split, so this reading is an inference from portfolios, not a measured result. Until more companies publish recyclability by format, an aggregate figure says little about where a company's EPR premium or PPWR exposure sits.

SPI analysis

"designed for recycling" or "recyclable by design" targets, which PepsiCo, Danone, Mondelēz, HEINEKEN, Colgate-Palmolive and Henkel report, are closer in spirit to the PPWR's design-for-recycling grades than to "recycled in practice". From 2035 the PPWR also asks whether packaging is recycled at scale, so a format that is recyclable by design but not collected and sorted could be at risk then, even if it meets the 2030 grade.

## Industry reaction

The four published statements quoted above, from the European Commission, PackUK, Recycle BC and Unilever, point the same way from different positions. The regulator sets the 2030 recyclability aim; the UK scheme administrator uses fees "to incentivise producers"; the Canadian stewardship agency charges film for the collection it is building; and the brand owner with the clearest disclosure moves part of its flexibles towards paper.

Industry coalitions show where companies are putting effort. Mondelēz co-chairs the Consumer Goods Forum's flexible plastic packaging taskforce and is a founding member of the US Flexible Film Initiative; Colgate-Palmolive's Hill's is a founding partner of the same initiative; Procter & Gamble sits in The Recycling Partnership's Film and Flexibles coalition; and Nestlé is a founding member of the UK's Flexible Plastic Fund (SPI Buyers Database profiles). Hindustan Unilever acquired a stake in Lucro Plastecycle, a recycled flexible plastics company, in March 2025. These are collection and recycling bets, the lever that matters most in acceptance-priced fee schemes and in the PPWR's 2035 at-scale test.

## What leaders should do now

1. **Head of packaging, by 31 March 2027:**  report recyclability and recycled content separately for rigid and flexible packaging, by market, so the flexibles gap is visible to the board and to investors.
2. **Packaging development lead, by mid-2027:**  rank every flexible SKU by its fee line in each market and by a provisional PPWR grade, flagging any format likely to fall below grade C.
3. **UK compliance lead, before the November 2026 notice of liability:**  check the RAM rating of each flexible format and budget red-rated tonnage at 1.2, 1.6 and 2.0 times amber for the next three years.
4. **Procurement lead, in the 2027 contract round:**  ask converters for mono-material PE or PP constructions and certified paper composites, priced against the per-tonne fee gap in each scheme's own currency.
5. **EU regulatory lead, within a month of publication:**  read the Article 6(4) delegated acts when adopted, due by 1 January 2028, and set the real redesign deadline from their entry into force.
6. **North America public affairs lead, through 2027:**  support collection of film in Oregon, Colorado and British Columbia, where moving a format onto an acceptance list is worth more than a polymer change.
7. **Chief sustainability officer, at the 2026 target review:**  align flexible packaging targets to the EU's earliest 2030 test date rather than a later corporate target year.

## Questions for your board

- What share of our plastic packaging is flexible, and what share of our non-recyclable tonnage does it make up?
- How much more do we pay each year in EPR fees for flexible formats than we would at rigid rates, scheme by scheme?
- Which of our flexible formats would fall below grade C if the PPWR test applied today, and what is our plan for them?
- How many of our UK flexible formats are rated red, and what will they cost when the multiplier reaches 2.0?
- Are our paper-based alternatives classed as paper or as composites in our main markets?
- Do our public recyclability targets distinguish design from collection and recycling at scale?

## What to watch

- **16 Oct 2026:**  California's SB 54 advisory board meets at CalEPA headquarters, after Circular Action Alliance submitted its plan on 15 June 2026 ([PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/)).
- **30 Nov 2026:**  PackUK targets the year 2 notice of liability, with fees modulated by RAM rating, by the end of November 2026 ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)).
- **1 Jan 2027:**  Fost Plus's 2027 rates apply, with PE films up 17.7%, and Ecoembes's 2027 table sets flexible film at EUR 1,269 per tonne.
- **1 Apr 2027:**  the UK red-rating multiplier rises to 1.6 ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)).
- **1 Jan 2028:**  the PPWR delegated acts setting design-for-recycling criteria and grades are due (Article 6(4); [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)).
- **1 Jan 2030:**  earliest date for the PPWR design-for-recycling test, grades A, B or C ([PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)).
- **1 Jan 2032:**  Minnesota's covered materials must be refillable, reusable, recyclable or compostable ([PR-US-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-006/)), SB 54's recyclable or compostable goal applies ([PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/)), and Ontario's 25% flexible plastic recovery rate applies ([PR-CA-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/canada/pr-ca-003/)).
- **1 Jan 2038:**  the PPWR minimum recyclability grade rises to grade B (recital 28; [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)).

## Methodology

- **Data used:**  the SPI Buyers Database (live on 14 October 2026, 148 targets, of which 41 are recyclability targets) and its company profiles; fee rows from the SPI EPR & Plastic Tax Calculator, consulted 12 to 14 October 2026, with SPI's fee market analysis of 14 October 2026 for 2025 and 2027 tables; SPI's rule analysis of [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/), [PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/), [PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/), [PR-US-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-006/), [PR-US-011](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-011/) and [PR-CA-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/canada/pr-ca-003/). SPI opened DG ENV's packaging page, PackUK's modulation statement and Recycle BC's 2026 fee schedule on 14 October 2026, and Unilever's Annual Report and Accounts 2025 on 13 October 2026.
- **Counting rules:**  ratios are within one scheme's own table; no fee amounts are converted, added or ranked across currencies; per-kg and per-lb rates are converted to per tonne in their own currency. Film and rigid pairs use the nearest line in the same polymer family, named in Exhibit 5.
- **Pricing types:**  the four types in Exhibit 6 are SPI's reading of each scheme's table and modulation rules.
- **Scenarios:**  the UK scenario holds amber at the year 2 illustrative rate for later years and applies the published red multipliers; the Dutch scenario applies Verpact's published discounts to its base rate. Both stay in one currency.
- **Cut-off:**  14 October 2026.
- **Limitations:**  company figures are self-reported, with different scopes and bases; SPI does not audit them. The Unilever format-mix estimate assumes its overall figure is the weighted result of its two formats on one basis. Italy's CONAI bands are not mapped to formats. UK year 2 fees are illustrative until PackUK's November 2026 calculation. PPWR criteria and grades depend on delegated acts not yet adopted, and the grade thresholds in Annex II are not stated. This is not legal advice; check with counsel where it applies.

## Sources

1. SPI Buyers Database, recyclability targets and company profiles, /data/packaging-buyers-database/, consulted 2026-10-14.
2. SPI EPR & Plastic Tax Calculator, 216 rate rows, and SPI fee market analysis for 14 markets, /data/epr-plastic-tax-calculator/, consulted 2026-10-14.
3. SPI Regulation Tracker and SPI rule analysis (PR-EU-010, PR-GB-003, PR-US-004, PR-US-006, PR-US-011, PR-CA-003), /data/packaging-regulation-tracker/, consulted 2026-10-14.
4. EUR-Lex, Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40, sections 2, 5 and 6, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202603084](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202603084), as given in SPI rule analysis, consulted 2026-10-14.
5. EUR-Lex, Regulation (EU) 2025/40, Official Journal HTML (recitals 28 to 35), [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040), consulted 2026-10-14.
6. European Commission (DG ENV), Packaging waste, [https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste_en), consulted 2026-10-14.
7. European Commission Green Forum, PPWR implementation timeline, [https://green-forum.ec.europa.eu/packaging-and-packaging-waste-regulation-implementation_en](https://green-forum.ec.europa.eu/packaging-and-packaging-waste-regulation-implementation_en), as given in SPI rule analysis, consulted 2026-10-14.
8. GOV.UK, PackUK producer disposal fees modulation statement (dated 28 June 2025), [https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement](https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement), consulted 2026-10-14.
9. GOV.UK (PackUK), Year 2 illustrative waste disposal fees, and PackUK operational plan 2026 to 2027, [https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging](https://www.gov.uk/government/publications/illustrative-waste-disposal-fees-2026-extended-producer-responsibility-for-packaging/year-2-illustrative-waste-disposal-fees-extended-producer-responsibility-for-packaging) and [https://www.gov.uk/government/publications/packuk-operational-plan/packuk-operational-plan-2026-to-2027](https://www.gov.uk/government/publications/packuk-operational-plan/packuk-operational-plan-2026-to-2027), as given in SPI rule analysis, consulted 2026-10-14.
10. Circular Action Alliance, 2026 Oregon Producer Fee Schedule and 2026 Colorado Producer Dues Schedule, [https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b2c9103be112d168e1b19/1765485713621/OR+2026+Fee+Schedule+Public.pdf](https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b2c9103be112d168e1b19/1765485713621/OR+2026+Fee+Schedule+Public.pdf) and [https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b45923163e42ba98d634f/1765492118120/CO+2026+Dues+Schedule+Public.pdf](https://static1.squarespace.com/static/64260ed078c36925b1cf3385/t/693b45923163e42ba98d634f/1765492118120/CO+2026+Dues+Schedule+Public.pdf), consulted 2026-10-13.
11. Recycle BC, 2026 Fee Schedule, [https://recyclebc.ca/wp-content/uploads/2025/10/Recycle-BC-2026-Fee-Schedule.pdf](https://recyclebc.ca/wp-content/uploads/2025/10/Recycle-BC-2026-Fee-Schedule.pdf), consulted 2026-10-14.
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13. Fost Plus, Green Dot rates 2026 and the 2026 and 2027 rates page, [https://www.fostplus.be/en/media/1930/download](https://www.fostplus.be/en/media/1930/download) and [https://www.fostplus.be/en/members/green-dot-rates](https://www.fostplus.be/en/members/green-dot-rates), as given in SPI fee market analysis, consulted 2026-10-14.
14. Verpact, Tarieven and Regeling Tariefdifferentiatie Plastic 2026, [https://www.verpact.nl/nl/tarieven](https://www.verpact.nl/nl/tarieven) and [https://www.verpact.nl/sites/default/files/2026-08/Regeling%20Tariefdifferentiatie%20Plastic%202026.pdf](https://www.verpact.nl/sites/default/files/2026-08/Regeling%20Tariefdifferentiatie%20Plastic%202026.pdf), as given in SPI fee market analysis, consulted 2026-10-14.
15. Repak, Regular Member fees 2025 and 2026, [https://repak.ie/images/uploads/downloads/Repak_Regular_Member_2026_Fees_Sheet.pdf](https://repak.ie/images/uploads/downloads/Repak_Regular_Member_2026_Fees_Sheet.pdf) and [https://repak.ie/images/uploads/downloads/Repak_Regular_Fees_2025.pdf](https://repak.ie/images/uploads/downloads/Repak_Regular_Fees_2025.pdf), as given in SPI fee market analysis, consulted 2026-10-14.
16. Citeo, Guide du tarif des emballages ménagers 2026 (updated 22 June 2026), [https://clients-cms.citeo.com/uploads/guide_du_tarif_des_emballages_menagers_2026_f9e4c5b4e6.pdf](https://clients-cms.citeo.com/uploads/guide_du_tarif_des_emballages_menagers_2026_f9e4c5b4e6.pdf), consulted 2026-10-13.
17. Valorlux, Grüner Punkt Tarife 2026 detailliert, and ARA, tariff rates 2026, [https://www.valorlux.lu/media/68e634367e399_gruener-punkt-tarife-2026-detailliert.pdf](https://www.valorlux.lu/media/68e634367e399_gruener-punkt-tarife-2026-detailliert.pdf) and [https://ara.at/uploads/Dokumente/Tarifbl%C3%A4tter/ARA-tariff-rates-2026.pdf](https://ara.at/uploads/Dokumente/Tarifbl%C3%A4tter/ARA-tariff-rates-2026.pdf), consulted 2026-10-12.
18. CONAI, EPR fee (Contributo Ambientale CONAI), and Sociedade Ponto Verde, Tabela VPV 2026, [https://www.conai.org/en/companies/services-for-managing-consortium-obligations-and-business-opportunities/epr-fee/](https://www.conai.org/en/companies/services-for-managing-consortium-obligations-and-business-opportunities/epr-fee/) and [https://www.pontoverde.pt/wp-content/uploads/2026/06/Tabela-VPV-2026.pdf](https://www.pontoverde.pt/wp-content/uploads/2026/06/Tabela-VPV-2026.pdf), as given in SPI fee market analysis, consulted 2026-10-14.
19. MPCA, Packaging Waste and Cost Reduction Act, and CalRecycle, Packaging EPR (SB 54), [https://www.pca.state.mn.us/business-with-us/packaging-waste-and-cost-reduction-act](https://www.pca.state.mn.us/business-with-us/packaging-waste-and-cost-reduction-act) and [https://calrecycle.ca.gov/packaging/packaging-epr/](https://calrecycle.ca.gov/packaging/packaging-epr/), as given in SPI rule analysis, consulted 2026-10-14.
20. CalRecycle, SB 343 Accurate Recycling Labels, [https://calrecycle.ca.gov/wcs/recyclinglabels/](https://calrecycle.ca.gov/wcs/recyclinglabels/), as given in SPI rule analysis, consulted 2026-10-14.
21. RPRA, Changes to the Blue Box Regulation (18 December 2025), [https://rpra.ca/2025/12/changes-to-the-blue-box-regulation-details-on-management-requirements-energy-from-waste-changes-to-collection-and-other-key-amendments/](https://rpra.ca/2025/12/changes-to-the-blue-box-regulation-details-on-management-requirements-energy-from-waste-changes-to-collection-and-other-key-amendments/), as given in SPI rule analysis, consulted 2026-10-14.
22. Unilever, Annual Report and Accounts 2025 (non-financial performance table p. 30; Sustainability Review p. 29), [https://www.unilever.com/files/unilever-annual-report-and-accounts-2025.pdf](https://www.unilever.com/files/unilever-annual-report-and-accounts-2025.pdf), consulted 2026-10-13.
23. ITC Limited, ESG Fact Book FY 2025-26, [https://www.itcportal.com/content/dam/itc-corporate/pdfs/itc-publications/itc-esg-factbook-2026.pdf](https://www.itcportal.com/content/dam/itc-corporate/pdfs/itc-publications/itc-esg-factbook-2026.pdf), as given in SPI Buyers Database, consulted 2026-10-14.
24. Mars, Mars debuts recyclable pet food pouches for WHISKAS (31 July 2025), and 2025 Sustainable in a Generation Plan report, [https://www.mars.com/news-and-stories/press-releases-statements/mars-debuts-recyclable-pet-food-pouches-for-whiskasr](https://www.mars.com/news-and-stories/press-releases-statements/mars-debuts-recyclable-pet-food-pouches-for-whiskasr) and [https://www.mars.com/sites/g/files/dfsbuz106/files/2026-06/MARS_SIGP_2025.pdf](https://www.mars.com/sites/g/files/dfsbuz106/files/2026-06/MARS_SIGP_2025.pdf), as given in SPI Buyers Database, consulted 2026-10-14.
25. Haleon plc, Annual Report and Form 20-F 2025 (SEC filing), [https://www.sec.gov/Archives/edgar/data/1900304/000110465926027443/hln-20251231x20f.htm](https://www.sec.gov/Archives/edgar/data/1900304/000110465926027443/hln-20251231x20f.htm), as given in SPI Buyers Database, consulted 2026-10-14.