# Plastic to paper packaging: four big buyers’ fibre switches, and the fee and PFAS tests each one must pass

> Plastic to paper packaging is now routine at Nestlé, McDonald's, Mondelēz and Tesco, and the fee rules mostly reward it: in France a paper pack can weigh up to 3.25 times the polypropylene film it replaces before its Citeo fee rises, and in Italy up to 19.0 times, by SPI's calculation. The catch is the barrier. Since 12 August 2026 every food-contact paper pack sold in the EU must meet the PPWR PFAS limits, and in the UK a paper pack with more than 5% plastic is rated as a fibre-based composite that pays more per tonne than plastic.

Publisher: Strategic Packaging Insights  
Published: 2026-11-04  
Last updated: 2026-11-04  
Page: https://www.strategicpackaginginsights.com/insights/plastic-to-paper-packaging-nestle-mcdonalds-mondelez-tesco-pfas-fees/

**Plastic to paper packaging is now routine at Nestlé, McDonald's, Mondelēz and Tesco, and the fee rules mostly reward it: in France a paper pack can weigh up to 3.25 times the polypropylene film it replaces before its Citeo fee rises, and in Italy up to 19.0 times, by SPI's calculation. The catch is the barrier. Since 12 August 2026 every food-contact paper pack sold in the EU must meet the PPWR PFAS limits, and in the UK a paper pack with more than 5% plastic is rated as a fibre-based composite that pays more per tonne than plastic.**

Four large packaging buyers now report fibre switches in their own documents, from Mondelēz's paper cookie trays to McDonald's fibre-based guest packaging. This SPI Ledger piece sets those reports side by side, prices the switch in France, Italy and the UK one currency at a time, and shows where PFAS rules and composite lines can erase the saving.

## Executive summary

Plastic to paper packaging has moved from pilots to whole ranges. On 4 September 2026 Mondelēz International said it had replaced rigid PET trays with 100% FSC-certified paper trays across 115 cookie products, 8 brands and over 25 European markets, removing more than 2,200 tons of virgin plastic a year. Nestlé's September 2026 Packaging Sustainability Strategy says it is replacing plastic with paper-based materials where possible and preferred by consumers. McDonald's reports that 96% of its primary guest packaging in Europe was fibre-based at year-end 2024. Tesco's 2026 Sustainability Report names paper tubs and cardboard trays among its switches.

The fee rules mostly reward the move, but not everywhere and not for every construction. **SPI analysis:**  in France, Citeo charges EUR 840.1 a tonne for polypropylene flexible packaging and EUR 258.1 for paper and board, so a paper pack can weigh 3.25 times the film before the weight fee rises. In Italy, CONAI's band 1 paper rate of EUR 45 a tonne against EUR 856 for plastic band B2.2, the band SPI assumes for the film, gives a break-even of 19.0 times. In the UK the answer turns on the plastic share: plain paper and board pays GBP 210 a tonne at the year 2 illustrative amber rate against GBP 455 for plastic, but a fibre-based composite pays GBP 525, more than the plastic it replaced.

The barrier is the hinge. Paper on its own does not keep coffee dry or grease off a bag, and the two classic fixes, a fluorinated coating or a plastic layer, now each meet a rule. Article 5(5) of Regulation (EU) 2025/40 bars food-contact packaging above 25 ppb for any single PFAS, 250 ppb for the sum and 50 ppm for total PFAS from 12 August 2026, with no sell-off period for stock placed after that date (Commission Notice C/2026/3084). A plastic layer avoids that test but can move the pack onto a composite line, and from the 2027 reporting year PackUK assesses any paper or board with more than 5% plastic by mass as a fibre-based composite (RAM 2027 guidance).

**SPI calculation:**  for one million flow-wrapped bars, a 3 g polypropylene wrapper costs EUR 2,520.30 in Citeo weight fees. A 6 g paper wrapper with a 12% plastic coating costs EUR 1,917.24, 23.9% less, but a 9 g paper wrapper with a 30% coating costs EUR 3,705.30, 47.0% more (Exhibit 7). In the UK the same 6 g paper wrapper costs GBP 3,150 against GBP 1,365 for the film at amber rates (Exhibit 8).

Leaders should price each switch per pack, not per tonne, check the coating against both PFAS limits and composite thresholds before the brief is frozen, and ask suppliers for fluorine screening data and fibre share by mass for every food-contact grade.

## Key findings

1. Mondelēz reports more than 2,200 tons of virgin plastic removed a year by paper cookie trays across 115 products in over 25 European markets, and a 300,000-tub Cadbury Heroes paper trial in Tesco from October 2025 (Mondelēz UK, 4 September 2026 and 22 October 2025).
2. McDonald's reports that fibre made up 82% of primary guest packaging globally and 96% in Europe at year-end 2024, and that 99.82% of guest packaging items had no intentionally added fluorinated compounds (October 2025 report; Purpose and Impact Report 2024 to 2025).
3. Nestlé used about 3.3 million tonnes of packaging in 2025, including about 0.86 million tonnes of plastic, so plastic was 26.1% of its packaging by weight, by SPI's calculation (Nestlé waste reduction page).
4. **SPI calculation:**  a paper pack can weigh 3.25 times a polypropylene film in France, 19.0 times a band B2.2 plastic in Italy and 2.17 times an amber plastic pack in the UK before its weight fee rises, if the paper stays on the plain paper line (Exhibit 2).
5. **SPI calculation:**  once the paper carries a barrier, the break-even falls to 2.63 times in France at 88% fibre, 12.2 times in Italy for a non-certified type B composite, and 0.87 times in the UK for a fibre-based composite, so in the UK a heavier coated paper always pays more than amber plastic (Exhibits 3 to 5).
6. Since 12 August 2026 food-contact packaging in the EU must stay below 25 ppb for any single PFAS, 250 ppb for the sum and 50 ppm for total PFAS; the UK's RAM 2027 rates food packaging red above 25 ppb from 1 January 2027 (Commission Notice C/2026/3084; RAM 2027 guidance).

## Why plastic to paper packaging is now a fee question

A fibre switch used to be a sustainability decision with a cost line attached. In 2026 it is also a fee decision, because Europe's packaging schemes now price materials far apart and the PPWR has tightened what a paper pack may contain. Three numbers decide the outcome for any pack: the weight rate of the plastic it replaces, the weight rate of the paper it becomes, and how much heavier the paper version is.

The weight ratio matters more than most briefs assume. Paper is denser than film and needs more mass for the same strength, so a flow-wrap or tray in paper is usually heavier than its plastic predecessor. **SPI analysis:**  the fee per pack falls only when the weight ratio stays below the ratio of the two rates. SPI calls that the break-even weight ratio, and Exhibit 2 sets it out for the plain paper lines.

The spread is wide because the two schemes price paper very differently. CONAI cut its paper base from EUR 65 to EUR 45 a tonne on 1 October 2025 and raised its plastic bands on 1 October 2026, so the gap widened on both sides within a year (SPI Italy fee-market note, from CONAI releases of 7 July 2025 and 25 May 2026). Citeo's paper and board line, at EUR 258.1 a tonne, is the second highest of the nine plain paper rates in SPI's euro scheme comparison; how that rate compares across nine schemes is covered in SPI's piece on [paper and board fees in euro schemes](https://www.strategicpackaginginsights.com/insights/paper-board-epr-fees-euro-schemes/), which this piece does not repeat.

SPI analysis

The ratios are a first screen, not a bill. They ignore per-unit charges, which Citeo applies to every sales unit whatever its material, and bonuses and maluses, which can move a line by 10% to 100%. But they answer the first question a packaging team asks: how much heavier can the paper version be before the fee stops helping?

## France: Citeo's rates and the coating on the paper

Citeo charges each material in a pack at its own weight rate, in euro cents per kilogram, which SPI converts to EUR per tonne (Citeo guide 2026, updated 22 June 2026). A paper pack with a plastic coating is therefore priced partly at the paper rate and partly at a plastic rate, so the coating's weight share drives the result (Exhibit 3).

Two details of the Citeo guide shape a fibre switch. First, paper with more than 50% recycled fibre earns a 10% cut on its paper weight part, and units changed after 30 September 2026 count only from the 2027 declaration (SPI France fee-market note, from the 2026 guide). Second, a unit that carries a malus for disrupting recycling cannot claim any bonus at all, so a paper pack that sorting centres reject gives up the recycled fibre saving too.

SPI analysis

For French packs the coating line is the open question. If Citeo treats the plastic layer of a paper laminate as complex packaging at EUR 1,400.1 a tonne rather than PE film at EUR 770.1, the break-even at 88% fibre falls from 2.63 to 2.13 times. SPI has not yet confirmed which line Citeo applies to a thin PE coating on paper; brands should ask Citeo before declaring 2026 placements in the January to February 2027 window.

## Italy: CONAI's fibre bands make paper cheap, and composites less so

CONAI grades paper packaging by its fibre share, with a lower rate for composites certified under the Aticelca 501 method, and grades plastic by whether it can be sorted and recycled and from which circuit it comes (SPI Italy fee-market note, from the CONAI 2026 guide). The 2026 table runs from EUR 45 a tonne for single-material paper to EUR 285 for type D composites below 60% paper, against EUR 856 for plastic band B2.2 and EUR 922 for band C from 1 October 2026 (CONAI 2026 table).

The CONAI fee also reaches the buyer by a different road. It is applied at the first transfer of empty packaging inside Italy, by the last producer or trader of that packaging when it sells to the first user, and it is shown on the invoice (SPI Italy fee-market note, from CONAI's EPR fee pages). A brand switching a tray from PET to paper in Italy therefore sees the saving on its converter's invoice, not in its own declaration, unless it imports packed goods and declares them itself.

SPI analysis

Italy is the market where a fibre switch is hardest to get wrong on fees. A paper pack in band 3.2 can weigh 12 times the plastic before it costs more. The risk sits in certification and fibre share data: an uncertified type C composite pays 41% more than a certified one, EUR 155 against EUR 110, by SPI's calculation, and a pack whose fibre share is not stated falls to type D at EUR 285.

## The UK: where coated paper costs more than plastic

UK packaging EPR prices household packaging by material and by recyclability rating, in GBP. PackUK's year 2 illustrative fees, published on 16 December 2025 and updated on 19 December 2025, set paper and board at GBP 190 green, GBP 210 amber and GBP 250 red a tonne, fibre-based composite at GBP 475, GBP 525 and GBP 630, and plastic at GBP 415, GBP 455 and GBP 545. The fees are illustrative, rounded to the nearest GBP 5, and still unconfirmed on 4 November 2026.

The classification line is now written down. RAM 2027 guidance says paper or board packaging with plastic content greater than 5% by mass must be assessed as fibre-based composite, and lists dry food packs with an inner barrier and plastic-coated moulded fibre trays among the non-liquid cartons in that class. A non-liquid carton is amber at application if non-paper content exceeds 10% by weight, and red if it exceeds 15% at collection or is laminated with plastic on both sides without clear disposal guidance (RAM 2027 guidance, updated 20 August 2026).

SPI analysis

This makes the UK the strictest of the three markets for barrier paper. In France and Italy a coated paper pack still pays less per tonne than plastic; in the UK, once plastic passes 5% of the pack, it pays more per tonne than amber plastic, so any added weight raises the bill. PackUK's modulation statement sets red at 1.2 times amber in 2026 to 2027, 1.6 times in 2027 to 2028 and 2.0 times in 2028 to 2029, which widens the gap for any composite rated red. The PFAS side of RAM 2027 is covered in SPI News on [RAM 2027 and PFAS](https://www.strategicpackaginginsights.com/news/uk-ram-2027-pfas-automatic-red-packaging/).

## A framework: four kinds of fibre switch

The four buyers' switches fall into four kinds, set by two questions: does the paper touch food, and does the pack need a barrier against oxygen, moisture or grease? Each kind meets a different rule first (Exhibit 6).

**Kind A, plain fibre swaps.**  These are the easiest on fees, because the pack stays on the plain paper line: EUR 45 a tonne in Italy and EUR 258.1 in France. But they are food-contact packs, and the Commission's guidance states that there are no exceptions for packaging containing recycled material, which matters for trays and bags made from recovered fibre (Commission Notice C/2026/3084, as quoted in SPI's [PFAS food-contact piece](https://www.strategicpackaginginsights.com/insights/pfas-food-contact-packaging-limits-paper-board/)).

**Kind B, barrier paper.**  Coffee is the hard case. Nestlé's 2024 release says its high-barrier paper refill for NESCAFÉ in the UK cuts packaging weight by 97% compared with the glass jar, which is a refill against a jar, not paper against film. For fee purposes the question is the plastic share: above 5% the UK classes the pack as a fibre-based composite, and in Italy every step below 95% fibre moves it up a band.

**Kind C, grease-resistant fibre.**  Quick-service packaging is the PFAS front line, because grease resistance was historically where fluorinated coatings were used. McDonald's sets an internal screen for packaging with oil and grease barrier coatings at 100 ppm of total organic fluorine (McDonald's packaging page).

**Kind D, outer packs.**  Where the paper holds wrapped goods, PFAS exposure is lower and the fee and weight test decides. Mondelēz's Cadbury Heroes tub holds individually wrapped sweets, and its paper multipack bags hold biscuit packs.

## Scenarios: one million wrappers in paper

SPI priced one pack, a confectionery flow-wrap, through three paper versions in each scheme, in EUR for France and Italy (Exhibit 7) and in GBP for the UK (Exhibit 8). The plastic wrapper is a 3 g polypropylene film; the paper versions are 1.5, 2.0 and 3.0 times heavier, with more coating as weight rises. Weights are SPI assumptions, not any company's specification.

**SPI calculation:**  the base case saves EUR 603.06 per million wrappers in France and EUR 2,148.00 in Italy. Each figure is a saving inside one scheme, not a total across the two. At one million units the sums are small, but they scale in a straight line with volume, so a line of 100 million wrappers carries 100 times the gap.

SPI analysis

The same paper wrapper is a saving in Italy, a saving or a cost in France depending on its weight, and a cost in the UK unless its plastic stays at 5% or less. A pan-European brand that designs one paper wrapper for all three markets should design to the UK's 5% line, because that is the only construction that saves fees everywhere in this model.

## Trays: what Mondelēz's switch means at French rates

Rigid trays are a cleaner case than wrappers, because a paper tray often needs no plastic layer. Citeo charges rigid PET packaging (tarif 6.3.3) at EUR 840.1 a tonne, so a tonne of PET tray can become up to 3.25 tonnes of plain paper tray before the French weight fee rises (Exhibit 9).

In practice: Mondelēz International.

Mondelēz's 4 September 2026 release says the paper trays replace rigid PET trays across 115 products and 8 brands, including LU, Milka, Granola, Cadbury, Marabou, Chips Ahoy!, Lacta and Freia, in over 25 European markets including the UK, Ireland, France, Germany, Poland, Spain and the Nordics. It puts the saving at more than 2,200 tons of virgin plastic a year, based on projected FY2026 production volumes compared with the previous outer wrap plus PET tray, and ties the move to its goal of a 25% cut in virgin rigid plastic by 2030. Its October 2025 release describes the 300,000 Cadbury Heroes paper tubs developed with DS Smith for Tesco, and paper-based multipack bags across Cadbury biscuits in the UK that reduce about 145 tonnes of virgin plastic. The releases give no paper tonnage, so SPI has not sized the fee effect for Mondelēz itself. This section covers Mondelēz's fibre switches only; its wider confectionery packaging is the subject of a separate SPI Ledger piece.

## PFAS-free paper packaging: what the limits demand of a fibre switch

The PFAS limit is the rule that turns a fibre switch from a design task into a compliance file. Article 5(5) of Regulation (EU) 2025/40 provides that from 12 August 2026 food-contact packaging shall not be placed on the market if it contains PFAS at or above 25 ppb for any PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS, or 50 ppm for total PFAS including polymeric PFAS (Commission Notice C/2026/3084, quoting the article; [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/) on the SPI Regulation Tracker).

Three points matter for a fibre switch, and SPI's [PFAS food-contact piece](https://www.strategicpackaginginsights.com/insights/pfas-food-contact-packaging-limits-paper-board/) covers the test sequence in full. First, there is no period for running down stock: packaging placed on the market before 12 August 2026 may stay on the market, but anything placed after must comply, and filled packaging is placed on the market when it is filled (Commission Notice C/2026/3084). Second, the limits are framed by concentration, not material, so they apply to plastic as well, but paper is where fluorinated grease barriers were used. Third, the UK goes further on totals: RAM 2027 rates food packaging red above 25 ppb for any individual or total PFAS, one tenth of the EU's 250 ppb sum limit on the face of the GOV.UK wording.

SPI analysis

For a buyer the PFAS limit and the composite line pull in opposite directions. Dropping a fluorinated coating for a plastic layer clears the PFAS test but can push the pack into a composite band; dropping it for a mineral or water-based coating may keep the pack on the paper line but needs fluorine data to prove the PFAS case. McDonald's own packaging page lists molded fiber, starch-based cups and mineral coatings for fiber among the plastic alternatives it promotes.

In practice: McDonald's.

McDonald's reports that most of its primary guest packaging is fibre-based, 82% globally and 96% in Europe at year-end 2024, and that 98.99% of fibre-based guest packaging came from recycled or certified sources (October 2025 report; Purpose and Impact Report 2024 to 2025). Its certified fibre must be at least 70% of a finished product's content, and wood fibre from Argentina, Cambodia, China, Indonesia, Laos, Malaysia and Vietnam must be FSC-certified or FSC-controlled (packaging page). It reports 99.82% of guest packaging items free of intentionally added fluorinated compounds at the end of 2024, against a goal of all primary guest packaging by the end of 2025; SPI has not yet confirmed an end-2025 figure. The switches it names are fibre McFlurry cups with flaps that phased out plastic lids in North America and moulded fibre sundae packaging in six European markets. Its reuse findings are covered in SPI's quick-service restaurant piece and not repeated here.

## What the four buyers report, and what they leave out

Each company reports its fibre switches differently, and none publishes the full set of numbers a fee model needs: the paper tonnage added, the weight ratio and the plastic share of the new pack (Exhibit 11). The [SPI Packaging Buyers Database](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/) holds each company's profile, with sources.

In practice: Nestlé.

Nestlé used about 3.3 million tonnes of packaging in 2025, including about 0.86 million tonnes of plastic, against 1.7 million tonnes of plastic in 2018 (waste reduction page; Ask Nestlé). **SPI calculation:**  plastic was 26.1% of its packaging by weight in 2025, and the plastic tonnage fell 49.4% from 2018, a fall the company's reported 28.0% cut in virgin plastic does not match because the two measures differ. Its September 2026 strategy says it is replacing plastic with paper-based materials where possible and preferred by consumers, names NESCAFÉ paper soft packs in Europe and paper-based compostable NESCAFÉ Dolce Gusto capsules in the Netherlands, and says it will engage with regulators and standard-setters so that paper-based innovations fit local recycling systems. The 2024 release adds a paperboard Vital Proteins canister in the United States with 90% less plastic, a paper body for the NESCAFÉ Cappuccino range in Europe instead of a plastic can, and names Smarties and KitKat as the start of its paper journey in confectionery. The strategy does not mention PFAS, coatings or EPR fee levels.

In practice: Tesco.

Tesco's 2026 Sustainability Report says it keeps removing plastic wherever possible and switching products to paper alternatives, and names a trial of about 300,000 Cadbury Heroes paper tubs with Mondelēz from October 2025 and cardboard trays for Booker's Farm Fresh catering mushrooms, forecast to save over 280 tonnes of plastic waste a year (pages 23 to 24). Its 2024/25 report adds over 57 million onion bags moved from plastic to paper and Finest dried pasta moved into paper packaging in November 2024 (page 13). The same 2026 report says its target that all paper and board used in the UK would be 100% sustainable by December 2025 was not met, and that it is retiring its voluntary packaging targets in favour of a 2035 circularity commitment. **SPI analysis:**  for a UK retailer the fee test sits with whoever is the producer of each own-label pack, and under RAM 2027 a coated paper own-label pack with more than 5% plastic is rated as a fibre-based composite.

SPI analysis

The missing number in Exhibit 11 is the paper tonnage added. Without it, neither a company nor its investors can tell whether a switch lowered the EPR bill, because the plastic removed is only half of the calculation. A buyer that publishes plastic removed should also hold the paper added per pack, by market.

## Where composites and recyclability rules come next

The PPWR adds a third test to the two above. Its design-for-recycling criteria under Article 6 take effect on the later of 1 January 2030 and two years after the delegated acts, so barrier choices made in 2026 should be checked against them (SPI tracker, [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/) interactions, from Commission Notice C/2026/3084). How each euro scheme classifies and prices laminates and mixed packs today, including the 5% EU composite threshold and the 80% to 95% lines in the schemes, is set out in SPI's piece on [composite packaging EPR fees](https://www.strategicpackaginginsights.com/insights/composite-multi-material-packaging-epr-fees/).

The Commission's timeline also sets a review of the Article 5(5) PFAS restriction for 12 February 2030, and recital 21 asks the Commission to assess whether to amend or repeal it so that it does not overlap with other Union acts (SPI tracker, [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/), from the Commission timeline and Regulation (EU) 2025/40). **SPI analysis:**  a buyer should plan on the limits staying until at least that review, because nothing in the texts SPI read suggests an earlier change.

## Industry reaction

> "Coffee is particularly sensitive to oxygen and humidity."

***Nestlé** , Head of the Coffee Business Unit, [Breaking barriers: Nestlé replaces more packaging with paper innovations](https://www.nestle.com/media/news/sustainable-paper-packaging-solutions), 2 September 2024*

The statement explains why Nestlé's paper work in coffee needed high-barrier paper, and why coffee sits in kind B of Exhibit 6.

> "This is a transformation we are proud to have engineered from the ground up."
>
>
>
> **Mondelēz International** , Biscuits Packaging Director, Europe, [release on paper trays across the UK and European cookies range](https://www.mynewsdesk.com/uk/mondelez-uk/pressreleases/mondelez-international-removes-2200-tons-of-virgin-plastic-per-year-introduces-paper-trays-across-its-flagship-uk-and-european-cookies-range-3464960), 4 September 2026
>
>
>
> "This switch is forecast to save over 280 tonnes of plastic waste annually."
>
>
>
> **Tesco PLC** , [Sustainability Report 2026](https://www.tescoplc.com/media/yjmlhji0/tesco-sustainability-report-2026.pdf), page 24, on cardboard trays for Booker's Farm Fresh catering mushrooms
>
>
>
> "We are committed to removing all intentionally added fluorinated compounds from our guest packaging materials globally."

***McDonald's** , [Packaging, Toys and Waste](https://corporate.mcdonalds.com/corpmcd/our-purpose-and-impact/our-planet/packaging-and-waste.html), corporate packaging page, consulted 4 November 2026*

## What leaders should do now

1. **Packaging development teams, before 2027 briefs are frozen:**  price every fibre switch per pack, using the break-even ratios in Exhibits 2 to 5, and record the weight ratio and plastic share by mass of each paper version.
2. **Brand owners selling in the UK, by 31 December 2026:**  check every coated paper pack against RAM 2027's 5% plastic line and its 10% and 15% non-paper flags, because 2027 data is assessed under RAM 2027 from 1 January 2027.
3. **Procurement leads, now:**  ask suppliers of every food-contact paper grade for total fluorine screening results tied to grade and lot, and for upstream fluorine statements where screening exceeds 50 mg/kg.
4. **French declarants, before the January to February 2027 window:**  confirm with Citeo which plastic line applies to the coating on paper packs, and claim the 10% recycled fibre reduction where paper holds more than 50% recycled fibre.
5. **Italian buyers, at the next invoice:**  check that converters invoice paper packs in the right CONAI band, hold Aticelca 501 certificates for type B and type C composites, and state fibre shares so packs do not fall to type D.
6. **Sustainability and investor relations teams, for the 2026 report:**  publish paper tonnage added alongside plastic removed, by market where possible.
7. **Legal and compliance teams, by 12 February 2030:**  keep a watch entry on the Commission's review of the Article 5(5) PFAS restriction, and check positions with counsel.

## Questions for your board

- Which of our paper switches lowered our EPR fees, market by market, and which raised them?
- How much paper tonnage did we add for each tonne of plastic we removed?
- Which of our coated paper packs pass 5% plastic by mass, and what do they cost under the UK's fibre-based composite line?
- Do we hold fluorine screening data for every food-contact paper grade placed on the EU market since 12 August 2026?
- Are we replacing fluorinated coatings with plastic layers, and have we priced the composite bands that follow?
- Who owns the paper tonnage and fibre share data our investors and schemes will ask for?

## What to watch

- **Nov 2026:**  Citeo opens the declaration space for 2026 placements (SPI France fee-market note).
- **30 Nov 2026:**  PackUK's planned date for the year 2 notice of liability; the illustrative fees in Exhibits 5 and 8 may change.
- **31 Dec 2026:**  Commission report on substances of concern under Article 5(2) of the PPWR due (Commission timeline).
- **1 Jan 2027:**  RAM 2027 applies to the 2027 reporting year, with the 5% fibre-based composite line and the PFAS automatic reds.
- **20 Jan 2027:**  CONAI periodic declarations for December 2026 or the fourth quarter due (SPI Italy fee-market note).
- **Feb 2027:**  Citeo's declaration window for 2026 placements closes.
- **1 Apr 2027:**  UK EPR year 3 starts, with red at 1.6 times amber (PackUK modulation statement).
- **12 Feb 2030:**  Commission review of the PPWR PFAS restriction due.

## Methodology

- **Data used:**  SPI Packaging Buyers Database profiles for Nestlé, McDonald's, Mondelēz International and Tesco, SPI Regulation Tracker rule [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/) and SPI fee-market notes for France and Italy (data as of 14 October 2026), brought up to date against the companies' own reports and releases, Commission Notice C/2026/3084, the Citeo 2026 guide, the CONAI 2026 table and GOV.UK pages, consulted 2 to 4 November 2026.
- **Company figures:**  each is the company's own, labelled with its document and date. SPI has not tested any pack, and no company figure is compared across companies as if it were on the same basis.
- **Calculations:**  break-even weight ratio is the plastic weight rate divided by the paper weight rate inside one scheme. Scenarios use a 3 g polypropylene flow-wrap and paper versions of 4.5 g, 6 g and 9 g at 95%, 88% and 70% fibre; these are SPI assumptions. EUR and GBP are calculated separately and never combined, summed or ranked against each other.
- **Assumptions:**  the plastic share of coated paper in France is priced at Citeo's PE flexible line, with the complex line shown as a sensitivity; Italian plastic is priced at band B2.2; UK ratings are SPI's reading of RAM 2027.
- **Cut-off:**  4 November 2026. UK year 2 fees were illustrative on that date.
- **Limitations:**  weight rates only, excluding Citeo per-unit charges, bonuses and maluses. SPI has not yet confirmed which Citeo plastic line applies to a coating on paper, the CONAI band for a mono PET biscuit tray, McDonald's end-2025 PFAS figure, or any company's paper tonnage. The Article 5(5) wording is as quoted in Commission Notice C/2026/3084; SPI has not yet confirmed it against the article text in the Official Journal. This is not legal advice; check with counsel.

## Sources

1. EUR-Lex: Commission Notice C/2026/3084, guidance document for Regulation (EU) 2025/40 on packaging and packaging waste (OJ C, 10 June 2026), section on Article 5(5). [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084) (consulted 4 November 2026)
2. EUR-Lex: Regulation (EU) 2025/40 on packaging and packaging waste, OJ L, 22 January 2025, recitals 21 and 24. [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 14 October 2026)
3. European Commission Green Forum: PPWR implementation timeline of implementing and delegated acts. [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) (consulted 14 October 2026)
4. Citeo: Guide du tarif des emballages ménagers mis en marché en 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) (rates checked 2 November 2026)
5. CONAI: EPR Fee (Contributo Ambientale CONAI), value table 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/) (consulted 4 November 2026)
6. CONAI: Guida al Contributo Ambientale 2026. [https://www.conai.org/download/guida-al-contributo-ambientale-2026/?tmstv=1791956169](https://www.conai.org/download/guida-al-contributo-ambientale-2026/?tmstv=1791956169) (consulted 14 October 2026)
7. GOV.UK (PackUK): Year 2 illustrative waste disposal fees, EPR for packaging, published 16 December 2025, updated 19 December 2025. [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) (consulted 4 November 2026)
8. GOV.UK (PackUK and Defra): RAM 2027 materials assessment guidance, updated 20 August 2026. [https://www.gov.uk/government/publications/assess-packaging-recyclability-recyclability-assessment-methodology-ram-2027/ram-2027-materials-assessment-guidance](https://www.gov.uk/government/publications/assess-packaging-recyclability-recyclability-assessment-methodology-ram-2027/ram-2027-materials-assessment-guidance) (consulted 4 November 2026)
9. GOV.UK (PackUK): 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](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 3 November 2026)
10. Nestlé: Packaging Sustainability Strategy, September 2026, pages 6, 11 and 13. [https://www.nestle.com/sites/default/files/2026-09/nestle-packaging-sustainability-strategy-en.pdf](https://www.nestle.com/sites/default/files/2026-09/nestle-packaging-sustainability-strategy-en.pdf) (consulted 4 November 2026)
11. Nestlé: Breaking barriers: Nestlé replaces more packaging with paper innovations, 2 September 2024. [https://www.nestle.com/media/news/sustainable-paper-packaging-solutions](https://www.nestle.com/media/news/sustainable-paper-packaging-solutions) (consulted 4 November 2026)
12. Nestlé: Packaging sustainability progress (Ask Nestlé), end of 2025 figures. [https://www.nestle.com/ask-nestle/environment/answers/packaging-sustainability-progress](https://www.nestle.com/ask-nestle/environment/answers/packaging-sustainability-progress) (consulted 4 November 2026)
13. Nestlé: Waste reduction. [https://www.nestle.com/sustainability/waste-reduction](https://www.nestle.com/sustainability/waste-reduction) (consulted 4 November 2026)
14. McDonald's: Purpose and Impact Progress Report 2024 to 2025, pages 12 to 14. [https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonalds_PurposeImpact_ProgressReport_2024_2025.pdf](https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonalds_PurposeImpact_ProgressReport_2024_2025.pdf) (consulted 4 November 2026)
15. McDonald's: The Complex Reality of Reusable Packaging in Europe, October 2025, page 4. [https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonald%27s%20Report_The%20Complex%20Reality%20of%20Reusable%20Packaging%20in%20Europe_13.10.pdf](https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonald%27s%20Report_The%20Complex%20Reality%20of%20Reusable%20Packaging%20in%20Europe_13.10.pdf) (consulted 4 November 2026)
16. McDonald's: Packaging, Toys and Waste. [https://corporate.mcdonalds.com/corpmcd/our-purpose-and-impact/our-planet/packaging-and-waste.html](https://corporate.mcdonalds.com/corpmcd/our-purpose-and-impact/our-planet/packaging-and-waste.html) (consulted 4 November 2026)
17. Mondelēz UK: Mondelēz International removes about 2,200 tons of virgin plastic per year, introduces paper trays across its flagship UK and European cookies range, 4 September 2026. [https://www.mynewsdesk.com/uk/mondelez-uk/pressreleases/mondelez-international-removes-2200-tons-of-virgin-plastic-per-year-introduces-paper-trays-across-its-flagship-uk-and-european-cookies-range-3464960](https://www.mynewsdesk.com/uk/mondelez-uk/pressreleases/mondelez-international-removes-2200-tons-of-virgin-plastic-per-year-introduces-paper-trays-across-its-flagship-uk-and-european-cookies-range-3464960) (consulted 4 November 2026)
18. Mondelēz UK: Mondelēz International and DS Smith partner on sustainable packaging initiative, introducing 300,000 Cadbury Heroes paper tubs, 22 October 2025. [https://www.mynewsdesk.com/uk/mondelez-uk/pressreleases/mondelez-international-and-ds-smith-partner-on-sustainable-packaging-initiative-introducing-300000-cadbury-heroes-paper-tubs-ahead-of-the-festive-season-3411662](https://www.mynewsdesk.com/uk/mondelez-uk/pressreleases/mondelez-international-and-ds-smith-partner-on-sustainable-packaging-initiative-introducing-300000-cadbury-heroes-paper-tubs-ahead-of-the-festive-season-3411662) (consulted 4 November 2026)
19. Tesco PLC: Sustainability Report 2026 (2025/26), pages 23 to 25. [https://www.tescoplc.com/media/yjmlhji0/tesco-sustainability-report-2026.pdf](https://www.tescoplc.com/media/yjmlhji0/tesco-sustainability-report-2026.pdf) (consulted 4 November 2026)
20. Tesco PLC: Sustainability Report 2024/25, May 2025, page 13. [https://www.tescoplc.com/media/wvkj1yic/tesco-sustainability-report-2025.pdf](https://www.tescoplc.com/media/wvkj1yic/tesco-sustainability-report-2025.pdf) (consulted 4 November 2026)
21. SPI Regulation Tracker: PR-EU-002, PPWR PFAS limits in food-contact packaging, data as of 14 October 2026. /data/packaging-regulation-tracker/european-union/pr-eu-002/
22. SPI Packaging Buyers Database: Nestlé, McDonald's, Mondelēz International and Tesco profiles, data as of 14 October 2026. /data/packaging-buyers-database/
23. SPI fee-market notes for France (Citeo) and Italy (CONAI), data as of 14 October 2026, from the Citeo 2026 guide, CONAI 2026 guide and CONAI releases of 7 July 2025 and 25 May 2026.