# Three rulebooks, the EU, the US states and the UK, reach 13 of 24 big packaging buyers at once

> Of the 24 brand owners and retailers profiled in depth in the SPI Packaging Buyers Database, EU packaging rules reach 18, US state packaging EPR reaches 17, the UK rules reach 15 and India's plastic EPR reaches 12, and 13 companies sit under all three of the EU, US and UK rulebooks.

Publisher: Strategic Packaging Insights  
Published: 2026-10-28  
Last updated: 2026-10-28  
Page: https://www.strategicpackaginginsights.com/insights/packaging-rules-market-exposure-24-brand-owners-retailers/

**Of the 24 brand owners and retailers profiled in depth in the SPI Packaging Buyers Database, EU packaging rules reach 18, US state packaging EPR reaches 17, the UK rules reach 15 and India's plastic EPR reaches 12, and 13 companies sit under all three of the EU, US and UK rulebooks.**

Strategic Packaging Insights (SPI) matched every market entry in those 24 profiles to the 79 rules in its Regulation Tracker. The result is a count of companies, not a sum of money: 111 market entries, 63 distinct rules and 307 company and rule pairs, and almost three quarters of those pairs sit in the EU, the UK and the US.

## Executive summary

Packaging law is now written market by market, and most companies track it the same way: one country, one scheme, one deadline at a time. That hides a simple question boards keep asking. Which rulebooks reach the most of our peers, and are we exposed to the same ones? SPI answered it by reading the exposure section of each of 24 depth profiles in its [Packaging Buyers Database](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/) and matching every entry to a rule in the [Regulation Tracker](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/).

The answer is concentration. The EU reaches 18 of the 24, US state packaging EPR 17 and the UK 15 (Exhibit 1). Of the 307 company and rule pairs SPI counted, 225 sit in those three markets, 73.3% by SPI's calculation. Thirteen companies, from Amazon and Nestlé to GSK and McDonald's, face all three at once.

India is the fourth pole. Its plastic EPR rules reach 12 of the 24, including four companies, Hindustan Unilever, ITC, Marico and Nestlé India, that sit under none of the EU, US or UK rules in SPI's profiles. For them, [PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/) and [PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/) are the whole rulebook, and the 2027 to 2028 recycled-content shares are the hardest step.

Beyond those four markets the map thins quickly: 9 companies in Southeast Asia, 5 each in Canada and Latin America, 4 in China and 3 in Africa. Those low counts partly reflect what SPI has written up rather than where the companies trade. On a wider reading that adds markets the profiles record but have not yet mapped, the Canadian count rises from 5 to 8 and the Southeast Asian count from 9 to 12 (Exhibit 11).

For leaders, three moves follow. Build one compliance view across the EU, US and UK, because those three rulebooks cover most of the obligations peers face. Treat India as its own programme with its own data. And check the markets SPI's profiles flag as present but unmapped, where obligations can arrive with little notice.

## Key findings

1. EU rules reach 18 of the 24 companies, US state packaging EPR 17, the UK 15 and India 12; no other market reaches more than 9 (SPI analysis of buyer profiles, 28 October 2026).
2. Thirteen of the 24 face the EU, US and UK rulebooks at once, and those 13 account for 214 of the 307 company and rule pairs, 69.7% by SPI's calculation.
3. Oregon's [PR-US-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-002/), Colorado's [PR-US-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-003/) and California's [PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/) each reach 16 companies, the most of any rule; [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/), [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/), [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/) and [PR-GB-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-002/) reach 15 each.
4. Of the tracker's 79 rules, 63 appear in at least one of the 24 profiles; 16 appear in none, including Minnesota's packaging EPR law ([PR-US-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-006/)) and the PPWR labelling rule ([PR-EU-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-003/)).
5. Five companies, Alibaba, Hindustan Unilever, ITC, Marico and Nestlé India, sit outside all three of the EU, US and UK rulebooks in SPI's profiles, and four of them face India's rules alone.
6. **SPI calculation:**  under a strict reading that drops conditional entries, the US count falls from 17 to 14 and Southeast Asia from 9 to 5; under a wide reading that adds markets the profiles record but have not mapped, Canada rises from 5 to 8 and China from 4 to 7 (Exhibit 11).

## How SPI built the map

Each of the 24 depth profiles carries an exposure by market section written by the SPI team between 13 and 14 October 2026. An entry names a market code, describes why the company is present, and lists the tracker rules that apply. SPI counted a company in a market when its profile has an entry for that market that names at least one rule. Member-state entries for France, Germany, Spain, Poland, Portugal and Ireland roll up into the EU count, and Vietnam, the Philippines and Indonesia roll up into Southeast Asia.

The 24 companies mix seven retailers, platforms and restaurant operators with 17 brand owners across food, home and personal care and pharmaceuticals (Exhibit 2). They are a subset of the 42 companies in the live database: the ones with depth profiles, not a sample chosen for exposure.

Two cautions shape every number that follows. First, an exposure entry is SPI's reading of where a company is likely to be an obliged producer, importer or brand owner; it is not a legal finding, and several entries are written conditionally. Second, the profiles write up the markets with the strongest presence, usually six to eight, so a company can trade in a market that does not appear. SPI's profile notes record, for example, that Mondelez's subsidiary list covers all of the tracker's national jurisdictions, while its profile writes up six. Exhibit 11 shows how the counts move when both cautions are applied.

## The rules that reach the most companies

Counting by rule rather than by market shows where obligations pile up (Exhibit 3). The three US state EPR laws in Oregon, Colorado and California each reach 16 of the 24. Four rules reach 15: the PPWR itself ([PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/)), its recyclability requirement ([PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/)), UK Plastic Packaging Tax ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)) and the UK EPR regulations ([PR-GB-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-002/)).

The long tail is just as telling. Of the 63 rules named at least once, 25 reach two companies or fewer. Sixteen tracker rules reach none of the 24 in SPI's written entries. Some are deliberately out of scope here, such as the EU own-resource rules ([PR-EU-017](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-017/), [PR-EU-018](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-018/)) that bind Member States rather than companies. Others are gaps in the mapping rather than in exposure: Minnesota's packaging EPR law, [PR-US-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-006/), is named in no profile, although several of the 16 companies reached in Oregon are national US sellers.

SPI analysis

The shape of Exhibit 3 matters for budgets. The seven rules at the top are all fee or tax rules, or design rules with a fixed date. Below them sit labelling, PFAS, reuse and format rules that each reach a handful of companies but can force a pack redesign. A compliance plan built only on the top of the chart will miss the rules most likely to change a specification.

## The full matrix, company by market

Exhibit 4 spreads each company's rule count across eleven markets. It is the view a group compliance team should hold for its own business: where the obligations are dense, where they are thin and where the column is empty.

Adding down the columns gives the weight of each market in the 307 pairs: 95 in the EU, 77 in the US, 53 in the UK, 31 in India, 19 in Canada, 11 in Southeast Asia, 8 in China, 6 in Latin America, 3 each in Africa and Japan and 1 in Australia. The EU column is the heaviest because the PPWR is not one obligation but a set of article-level duties, and because member-state rules such as France's AGEC ([PR-FR-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-001/), [PR-FR-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-003/)) and Spain's plastic tax ([PR-ES-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/spain/pr-es-001/)) sit on top of it.

Retailers and brand owners show the same pattern at different strengths. Among the seven retailers, platforms and restaurant operators, the EU reaches 5, the UK 4, the US 4 and India 2. Among the 17 brand owners, the EU reaches 13, the US 13, the UK 11 and India 10. The four pharmaceutical and consumer health companies are all in the EU and US columns, and three of them, all but Sanofi, in the UK.

## Four exposure archetypes

Sorting the 24 by how many of the three big rulebooks reach them gives four groups (Exhibit 5). Each group needs a different compliance set-up, and each tells a supplier something different about the customer it serves.

**Triad globals.**  These 13 companies carry 12 to 24 rule links each. Their challenge is not finding the rules but running three regimes with different units: PPWR articles in the EU, state programmes priced by Circular Action Alliance in Oregon and Colorado, and PackUK's fees and Plastic Packaging Tax in the UK. Seven of the 13 also face India.

**Two of three.**  The two UK grocers, Tesco and ALDI UK, combine the UK with Ireland and, for Tesco, Central Europe. Ahold Delhaize, Henkel and Sanofi combine the EU with the US. For these five the missing third market is usually a mapping question, not a commercial one: SPI's profiles record no UK selling entity for Henkel or Sanofi, and say so.

**US plus emerging markets.**  Walmart is alone in this group. Its Form 10-K for fiscal 2026 lists Walmart International operations in 18 countries, including Canada, Chile, China, India and South Africa, and no EU country. Its rule links run through US state EPR, Ontario's Blue Box and India's EPR via Flipkart.

**Asia rulebook.**  Four of the five are India-based or India-listed companies whose profiles cover India only; the fifth, Alibaba, faces Chinese express-packaging rules and Southeast Asian EPR through Lazada. For this group the EU, UK and US debate is background; [PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/)'s 2027 to 2028 recycled-content step is the foreground.

## United Kingdom: one tax, one EPR scheme, 15 companies

The UK is the most uniform of the big three (Exhibit 6). Every one of the 15 companies with a UK entry is linked to both Plastic Packaging Tax and the EPR regulations, because both rest on the same producer tests across all four nations. Thirteen are also linked to [PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/), the modulated Year 2 fees; Kimberly-Clark's and McDonald's UK entries name the EPR regulations without it.

The narrow deposit count is a mapping choice worth noticing. Only Danone, Tesco and ALDI UK have UK entries that name the deposit rules, though several other profiles describe drinks sold in the UK. The tracker's UK notes say Exchange for Change opened phase 1 registration on 29 September 2026, with phase 2 role-specific registration for drinks producers due in January 2027, so the count is likely to rise as profiles are refreshed.

The tax line carries the sharpest date. From 1 April 2027 pre-consumer plastic stops counting as recycled for the tax and certified mass balance becomes available for chemically recycled plastic (tracker notes on [PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)). The same day, EPR Year 3 starts with the red fee multiplier at 1.6 ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)). Fee detail is in the [UK EPR Year 2 piece](https://www.strategicpackaginginsights.com/insights/uk-epr-year-2-ram-ratings-packaging-bill/), and fee levels per tonne across markets are in [EPR fees per tonne in 2026](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/).

In practice: Tesco.

Tesco's Sustainability Report 2026 says 99% of UK Own Brand packaging was recyclable in 2025/26, with 87% recyclable at kerbside, and that under EPR it takes full responsibility for its Own Brand products while suppliers remain accountable for branded goods (packaging section). Its deposit footprint already spans three systems: 345 reverse vending machines in its 191 Irish stores, where almost 8.4 million customers returned 247 million containers in the scheme's second year; a Hungarian scheme launched in 2025 in 152 stores; and a Slovak scheme in 135 stores since 2022 (packaging section). In SPI's map Tesco is a two-of-three company, but its UK rule count of 5 is level with Danone's and behind only ALDI UK's 7.

## United States: three states carry the load

US exposure is a state story (Exhibit 7). Sixteen of the 17 companies with a US entry are linked to all three of Oregon, Colorado and California. The 17th, Ahold Delhaize, is linked instead to Maine ([PR-US-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-001/)) and Maryland ([PR-US-007](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-007/)) through its East Coast banners, and its profile states that none of its banners is listed in Oregon, Colorado, California or Minnesota.

The three big states run on different clocks. Oregon's producers have had to belong to the producer responsibility organisation since 1 July 2025, and first life cycle evaluations from listed large producers are due by 31 December 2026 (tracker record [PR-US-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-002/)). Colorado's first annual dues on covered materials became payable in January 2026 ([PR-US-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-003/)). California's permanent SB 54 regulations took effect on 1 May 2026, producers had until 1 June 2026 to join the PRO, register as independent or seek exemption, and the first 10% single-use plastic reduction step falls on 1 January 2027 ([PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/)).

Washington's new EPR law, [PR-US-008](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-008/), is linked to only Pfizer and Sanofi, and Minnesota's to nobody. That reflects how the profiles were written, not where the companies sell: most of the 16 multi-state companies are national sellers. **SPI analysis:**  a company already registered in Oregon, Colorado and California should assume Minnesota, Maryland and Washington apply until it has evidence otherwise. The [US state EPR piece](https://www.strategicpackaginginsights.com/insights/us-state-packaging-epr/) sets out the state-by-state duties.

For the three drug makers, the US count carries a caveat. GSK's, Pfizer's and Sanofi's entries each say the state laws apply to cartons, shippers and pallets unless a state drug or device exemption applies, and that the exemptions differ by state and have not been mapped. SPI has not yet confirmed how each state treats medicinal packaging.

In practice: Walmart.

Walmart's FY2026 ESG waste page reports private-brand plastic packaging at an estimated 12.0% recycled content in North America and 10.7% globally, up from 8.2% and 7.6% the year before, with 64.3% of global private-brand packaging recyclable, reusable or industrially compostable, and private-brand virgin plastic 4.12% above the FY2021 baseline. Those figures sit against five US rules in SPI's map, including California's AB 793 for private-brand drinks bottles ([PR-US-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-009/)) and New Jersey's [PR-US-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-010/). Its profile also cites a Canadian bag statement and a 16% recycled multipack water bottle, which SPI has not yet confirmed against the company's current pages.

## European Union: the PPWR plus a national layer

The EU count of 18 hides two layers (Exhibit 8). The first is the PPWR itself, which has applied since 12 August 2026 (tracker record [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/)). Fifteen companies are linked to the regulation as a whole and 15 to its recyclability rule, [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/), whose design-for-recycling test applies from 1 January 2030 at the earliest. The second layer is national: French marking and single-use rules, Spain's plastic tax and decree, Germany's new packaging law and deposit systems in Poland, Portugal and Ireland.

Two features stand out. PFAS ([PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/)) reaches seven companies: the six food and restaurant companies with EU entries, General Mills through its France entry, and Ahold Delhaize for its own brands. It is the EU rule that bites first, because it applied with the rest of the regulation in August 2026. And the recycled-content rule, [PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/), reaches only 6 companies in SPI's map, because the profiles name it where plastic is a large part of the mix: Henkel, Reckitt, Haleon, Mondelez, Colgate-Palmolive and ALDI UK.

The national layer is uneven. France is named in six profiles and Germany in four, while Poland and Portugal each appear once, through Danone's deposit role in Poland and Ahold Delhaize's unconsolidated Portuguese joint venture. The [PPWR after August 2026 piece](https://www.strategicpackaginginsights.com/insights/ppwr-after-august-2026/) covers the regulation's staged dates in detail.

## India and the rest of Asia

India's rules reach 12 of the 24 (Exhibit 9), more than any market outside the EU, the US and the UK. Every one of the 12 is linked to [PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/), the EPR guidelines in Schedule II of the Plastic Waste Management Rules, and 11 to [PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/), the recycled-content shares that G.S.R. 237(E) of 31 March 2026 recast (tracker records). Amazon's India entry names only [PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/).

The Indian calendar is fixed and close. The 2027 to 2028 recycled-content shares apply from 1 April 2027: 50% for Category I rigid packs, 20% for Category II and 10% for Category III, with reuse shares for brand owners rising the same day ([PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/), [PR-IN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-003/)). Annual returns for 2026 to 2027 are due on the CPCB portal by 30 June 2027 ([PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)). The [India rules piece](https://www.strategicpackaginginsights.com/insights/india-plastic-packaging-rules-2026/) covers the categories.

In practice: ITC and Hindustan Unilever.

ITC's BRSR for the year to March 2026 reports about 31,200 tonnes of plastic waste recycled and about 41,300 tonnes safely disposed, and states that it is in compliance with the EPR requirements of the 2016 Rules. Hindustan Unilever's plastics page gives a footprint of about 128,000 tonnes for 2025 and a cumulative EPR quantity of about 837,000 tonnes, and says it meets its EPR obligation in full at national level. Neither company has an EU, UK or US entry in SPI's map, so India's rules are their whole exposure. Their fuller story is in [India FMCG plastic EPR](https://www.strategicpackaginginsights.com/insights/india-fmcg-plastic-epr-hul-itc-marico-nestle/).

Southeast Asia reaches 9 companies but none deeply: each carries one to three rules there. Indonesia's roadmap rule and the Philippine EPR law each reach 4, and Vietnam's Decree 110/2026 reaches 3. Under [PR-PH-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/philippines/pr-ph-001/), each obliged enterprise must show recovery or offset equal to 60% of its 2025 footprint by 31 December 2026 (tracker jurisdiction notes); Colgate-Palmolive's, Kimberly-Clark's and Nestlé's Philippine entries are written conditionally because their large-enterprise status has not been confirmed.

China reaches 4 companies, through the excessive packaging standard for food and cosmetics ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/)) and the express-packaging rules that bind delivery firms. Alibaba's FY2026 results put its China E-commerce Group revenue at RMB 554,217 million out of RMB 1,023,670 million, so most of its business sits under Chinese rules that the EU, UK and US debate never touches.

## What the companies' own latest reports say

SPI brought each company's key market and packaging facts up to date from its own latest report (Exhibit 10). Where a buyer profile cites a fact without a source SPI could match to the company's own current publication, the table says SPI has not yet confirmed it.

Three things stand out. First, only nine of the 24 sources name EPR, a plastic tax or the PPWR in the passages SPI read: Colgate-Palmolive's 10-K, Danone, Henkel, Kimberly-Clark, Reckitt and Tesco, and the EPR statements of Hindustan Unilever, ITC and Marico. For most, the regulatory exposure in Exhibit 4 is larger than the company's own packaging report suggests.

Second, several reports are a year behind the rules. Reckitt's 2025 report gives 2024 packaging data and says 2025 data would follow in mid-2026, and Kraft Heinz's 2025 ESG Report covers fiscal 2024. SPI has not yet confirmed later figures for either. Third, scopes differ: Haleon reports a year to 30 June, Walmart a fiscal year to 31 January, and ALDI UK's footprint is for calendar 2023.

In practice: Mondelez International.

Mondelez's FY2025 results put Europe at USD 15,027 million of USD 38,537 million of net revenues, the largest of its four regions. Its goals page reports 96% of packaging designed to be recyclable, an 11.5% cut in overall virgin plastic against 2020 and 3.7% recycled plastic content against a 5% goal for 2030. In SPI's map it carries 16 rule links across six markets, and its profile notes that its subsidiary list covers every national tracker jurisdiction. That gap between six written markets and a near-global footprint is why it moves most in the wide scenario below.

## Scenarios: how the counts move

The counts in Exhibit 1 rest on one counting rule. Exhibit 11 tests it both ways. The strict case drops entries that SPI's profiles write conditionally or with an open question: the three drug makers in the US pending state exemptions, General Mills in the UK because its listed UK entity is a joint venture, Walmart in India because Flipkart's filing role is open, Alibaba and three Philippine subsidiaries in Southeast Asia, Haleon in China and Australia's bill. The wide case adds markets the profiles record as present but have not written up.

The assumptions behind the wide case are specific. India adds McDonald's, whose Indian restaurants are licensed, and Nestlé at group level through its listed Indian subsidiary. Southeast Asia adds Reckitt (Vietnam and Indonesia), Haleon (Indonesia) and McDonald's (Philippines). Canada adds Haleon and Henkel, recorded as present at region level, and Mondelez. China adds Danone, Reckitt and McDonald's. Africa adds Haleon and GSK, whose presence is manufacturing or third-party distribution, and Mondelez.

SPI analysis

The EU, the UK and the US are robust. Their counts move by three at most between the strict and wide readings, so a peer benchmark built on them is safe. In most other markets the count rises by three in the wide case, a large step on a base of two to five, and that says more about mapping than about exposure. A company that trades in Canada, Southeast Asia or Latin America should not take a low peer count as evidence of low risk.

## Industry reaction

> "We monitor regulatory requirements, including Extended Producer Responsibility (EPR) and plastics taxes, and manage related risks through materials innovation, supplier engagement, and strategic partnerships."

***Kimberly-Clark** , brand owner, [2025 Sustainability Report](https://www.kimberly-clark.com/-/media/feature/kcc/corporate/pdf/key-download-pdf/KMB-2025-Sustainability-Report_Final.pdf), June 2026*

The same page of the report lists mandatory collection of packaging in Brazil, Colombia and Chile among its Latin American circularity items, which matches the two Latin American rules in its SPI profile.

> "We advocate for effective eco-modulation within Extended Producer Responsibility (EPR) schemes."

***Henkel** , brand owner, [Sustainable packaging](https://www.henkel.com/sustainability/sustainable-packaging), consulted 28 October 2026*

Henkel's page pairs that position with 2030 goals of at least 35% recycled plastics in consumer-product packaging and 100% of packaging designed for recycling, the two measures [PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/) and [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/) will test in its seven EU rule links.

> "Danone has played a key role in the launch of the Deposit Return Scheme in Poland in October 2025."

***Danone** , brand owner, [Packaging, towards a circular economy](https://www.danone.com/impact/planet/packaging-positive-circular-economy.html), consulted 28 October 2026*

Danone's page also says it pays EPR fees in markets where EPR is legislated and that it was a founding member of France's first EPR organisation, now Citeo.

> "We have also been appointed Deputy Chair of the Scheme Administrator Steering Group (SASG) for PackUK."

***Tesco** , retailer, [Sustainability Report 2026](https://www.tescoplc.com/media/yjmlhji0/tesco-sustainability-report-2026.pdf), packaging section*

## The limits of a count

A count treats a light duty and a heavy one alike. Oregon's EPR law and New Jersey's recycled-content law each add one link, though they ask very different things of a company. The heat table gives weight by number of rules, not by cost or effort, and SPI does not attach a money figure to any cell. Fee levels for the schemes that publish them are in the [EPR fees per tonne piece](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/), each in its own currency.

The written entries also favour the markets SPI's profiles chose to describe, typically the largest by sales or the best documented. Where a profile says a fact is SPI's reading, such as Kraft Heinz's dippots under [PR-EU-008](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-008/) or the category placement of Nestlé India's packs, the count includes the market but the specific obligation remains an open question. Companies should confirm obligations with their compliance scheme and check with counsel where it applies.

## What leaders should do now

1. **Group compliance leads, by 31 December 2026:**  build one register of obligations across the EU, US and UK using the rule list in Exhibit 3, because those three markets hold 225 of the 307 rule links among peers, and assign one owner per rule.
2. **US regulatory teams, by 1 January 2027:**  confirm registration status in Minnesota, Maryland and Washington as well as Oregon, Colorado and California, and record the reason wherever you conclude a state does not apply.
3. **UK packaging and tax teams, by 1 April 2027:**  re-test every plastic component against the 30% line without pre-consumer plastic, and price red-rated items at the Year 3 multiplier of 1.6.
4. **India brand-owner teams, before 1 April 2027:**  model Category I, II and III packs against the 50%, 20% and 10% recycled-content shares for 2027 to 2028, and line up certificates for the 30 June 2027 return.
5. **Regional heads for Canada, Southeast Asia and Latin America, by the end of Q1 2027:**  list every market where the business is present but obligations are unmapped, starting with the wide-case additions in Exhibit 11.
6. **Sustainability reporting teams, for the 2026 report cycle:**  add a market-by-market regulatory exposure table to the packaging section, since most of the 24 companies' current reports name few of the rules that reach them.
7. **Suppliers and converters, at the next customer review:**  ask which of the four archetypes each customer belongs to, and align specifications with the rules that reach the most of your customers.

## Questions for your board

- How many of the 63 rules that reach our peers reach us, and who owns each one?
- Are we a triad company, and if so, is one team running the EU, US and UK regimes together or three teams running them apart?
- Which markets do we trade in that our compliance register does not list?
- What is our position on the 1 April 2027 changes in the UK and India, the two dated steps closest to us?
- Does our sustainability report name the packaging laws that reach us, or only our voluntary targets?
- Where our exposure depends on a conditional reading, such as an exemption or a size threshold, when will we have a firm answer?

## What to watch

- **30 Nov 2026:**  PackUK's first Year 2 notices of liability are due by the end of November, the first modulated fee bill for the 13 of the 24 linked to [PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/).
- **31 Dec 2026:**  Oregon's listed large producers file first life cycle evaluations ([PR-US-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-002/)), and obliged Philippine enterprises must show 60% recovery of their 2025 footprint ([PR-PH-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/philippines/pr-ph-001/)).
- **1 Jan 2027:**  California's first 10% single-use plastic reduction step and next covered material list ([PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/)).
- **1 Apr 2027:**  UK tax changes and EPR Year 3 start ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/), [PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)), and India's 2027 to 2028 recycled-content and reuse shares apply ([PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/), [PR-IN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-003/)).
- **31 May 2027:**  Ontario producers file supply and performance reports on 2026 data ([PR-CA-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/canada/pr-ca-003/)).
- **30 Jun 2027:**  India's annual EPR returns for 2026 to 2027 are due on the CPCB portal ([PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)).
- **1 Oct 2027:**  deposit return starts in England, Northern Ireland and Scotland ([PR-GB-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-004/), [PR-GB-005](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-005/)).

## Methodology

- **Data used:**  the exposure-by-market sections of 24 depth profiles in the SPI Packaging Buyers Database, written 13 to 14 October 2026; the 79 rules in 25 jurisdictions in the SPI Regulation Tracker and their depth notes; and each company's own latest report or page, consulted 28 October 2026.
- **Counting rules:**  a company is counted in a market when its profile has an exposure entry for that market naming at least one tracker rule. A rule is counted once per company. Member-state entries roll into the EU; Vietnam, the Philippines and Indonesia into Southeast Asia; Brazil, Chile and Colombia into Latin America; Kenya and South Africa into Africa. US counts in Exhibit 1 use the state packaging EPR laws only.
- **Calculations:**  shares are of 307 company and rule pairs. All figures are counts. No money is added, averaged or compared, and company sales figures are shown only in their own currency.
- **Scenarios:**  strict and wide cases follow the conditions and presence notes in each profile, as described under Exhibit 11; they are SPI choices, not legal findings.
- **Cut-off:**  28 October 2026.
- **Limitations:**  exposure entries are SPI's reading, not a determination of legal status. Profiles write up the strongest markets, so absence from a market is not evidence of no exposure. Medicinal packaging exemptions and size thresholds are not mapped. Confirm obligations with your scheme and check with counsel where it applies.

## Sources

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