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

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 45 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), the UK’s fee modulation (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.

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

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.

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.

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.

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.

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.

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.

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).

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.

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.

PPWR: the staged recyclability rule

PR-EU-010 is where flexible packaging stops being a cost question and becomes a market-access one. The Commission states the aim plainly.

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).

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, MPCA). California’s SB 54 requires all covered packaging to be recyclable or compostable by 1 January 2032 (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). 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).

Where brand owners stand on recyclability

The SPI Buyers Database records 45 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).