# Tesco and ALDI ban named packaging materials, while Walmart and Ahold Delhaize steer suppliers through portfolio goals they have mostly not yet met

> Of the four grocers, Tesco and ALDI publish named lists of packaging materials that suppliers must not use, Walmart and Ahold Delhaize mainly set group-level goals and principles, and only one of the seven 2025 packaging goals that Walmart and Ahold Delhaize published has a confirmed hit.

Publisher: Strategic Packaging Insights  
Published: 2026-10-26  
Last updated: 2026-10-26  
Page: https://www.strategicpackaginginsights.com/insights/retailer-packaging-supplier-rules-compared/

**Of the four grocers, Tesco and ALDI publish named lists of packaging materials that suppliers must not use, Walmart and Ahold Delhaize mainly set group-level goals and principles, and only one of the seven 2025 packaging goals that Walmart and Ahold Delhaize published has a confirmed hit.**

Each of the four retailers acts as a second packaging regulator for the brands on its shelves, with its own definitions of "recyclable", "recycled content" and "reduction". This piece compares what each one asks of suppliers on five levers, using each retailer's latest dated policy, supplier guidance and report, and shows where UK, EU and US law now does the same job.

## Executive summary

Large grocers now write packaging rules of their own, and those rules bind every own-brand supplier and, at Tesco, branded suppliers too. Strategic Packaging Insights (SPI) compared the latest dated supplier documents and reports of four retailers in the [SPI Packaging Buyers Database](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/): Tesco, Walmart, ALDI (ALDI UK with the ALDI SOUTH Group and the shared ALDI Recyclability Guidelines) and Ahold Delhaize. The sister piece on [the food giants' packaging pledges](https://www.strategicpackaginginsights.com/insights/fmcg-packaging-pledges-compared/) looked at what brand owners promise; this one looks at what their retail customers demand.

The four differ more in form than in direction. All four push recycled content, recyclability and less plastic. But Tesco's UK guidelines, version PM08 dated 020226 in the list's own code, name prohibited formats and materials, from PVC and polystyrene to compostable plastics and glitter, and require packaging data to go to Valpak. ALDI's Recyclability Guidelines, version 4.0 of April 2025, accept packaging only at amber rating or better and expect light green. Walmart and Ahold Delhaize lean on portfolio goals, a playbook and a supplier code that "urges" four steps (Exhibit 1).

Results are thin where goals are group-wide. Walmart's FY2026 page, dated 29 July 2026, shows all four of its 2025 private-brand goals short: 64.3% recyclable, reusable or industrially compostable against 100%, recycled content of 12.0% in North America against 20%, and virgin plastic 4.12% above its FY2021 baseline instead of 15% below. Ahold Delhaize beat its virgin plastic goal, at 10.9% below 2021, but SPI has not yet confirmed its 2025 recycled-content and recyclability results. ALDI UK has published no outcome for its 50% recycled-content and 50% plastic-reduction goals for 2025.

Definitions decide what a supplier must deliver. Tesco counts recyclability by weight across UK routes, Walmart uses the Ellen MacArthur Foundation definition and counts industrial compostability, Ahold Delhaize scores plastic only and "in practice and at scale", and ALDI scores against mechanical recycling in each country. A compostable tray can count as success at Walmart and Ahold Delhaize and be prohibited at Tesco.

For a supplier brand, the practical answer is to design once to the strictest list it sells into, document recycled content per component, and hold data in each retailer's own unit. Tesco has retired its voluntary targets and handed the job to UK Extended Producer Responsibility (EPR), Plastic Packaging Tax and deposit return. **SPI analysis:**  the other three face the same kind of laws in the UK, the EU and US states, so their supplier asks are likely to converge on statutory floors (Exhibit 12).

## Key findings

1. Tesco's 2024 requirements (PM06) list 17 prohibited formats and materials, and its 2026 list (PM08) repeats them in the same block, adds packaging with batteries and sets a 15% non-paper content limit for paper and board based on the UK Recyclability Assessment Methodology (RAM).
2. Walmart reports 64.3% of global private-brand packaging recyclable, reusable or industrially compostable in FY2026, 81.1% of its private-brand plastic packaging designed for recycling, and recycled content of 12.0% in North America and 10.7% globally (29 July 2026).
3. Ahold Delhaize cut virgin plastic in own-brand primary packaging by 10.9% against 2021 in 2025, beating a 5% goal; its latest confirmed recycled-content share is 15.7% for 2024, against 25% for 2025 (reports of 11 February 2026 and 2024).
4. ALDI's Recyclability Guidelines V4.0 (April 2025) cover own-brand packaging across ALDI Nord and ALDI SOUTH, count only mechanical recycling and say PVC is "strictly to be avoided"; ALDI UK's plastic footprint page still shows 2023 data, 124,940.15 tonnes.
5. **SPI analysis:**  compostable plastics are prohibited on Tesco's red list and not counted as recyclable by ALDI's guidelines, but count toward the 2025 goals of Walmart ("industrially compostable") and Ahold Delhaize ("compostable").
6. **SPI calculation:**  at their latest one-year pace, Walmart's recycled content would reach its North America goal in about 2.1 years, and Ahold Delhaize's in about 10.3 years from 2024 (Exhibit 11).
7. **SPI calculation:**  a supplier with 1,000 tonnes of rigid plastic at 10% recycled content needs 100 to 400 more tonnes of recycled resin to match these retailers' stated levels, depending on the retailer (Exhibit 10).

## The documents that bind suppliers

Retailers publish packaging rules in three kinds of document: a supplier specification, a supplier code of conduct and a sustainability report. Only the first two speak to suppliers directly. Exhibit 2 lists the latest dated document of each kind that SPI found for each retailer, as at 21 October 2026.

The scope of each document matters as much as its content. Tesco's 2026 list is titled for "Own branded and Branded" packaging, so a national brand selling into Tesco UK is inside it. Walmart's playbook says it covers private brand and national brand packaging, but its numeric goals cover private brands only. ALDI's guidelines cover own-brand packaging from national and international suppliers. Ahold Delhaize's Standards of Engagement apply to "every Supplier" that sells goods or services to the group, but its packaging goals count own-brand primary packaging only.

In practice: Tesco.

Tesco's Sustainability Report 2026 says 99% of UK Own Brand packaging by weight was recyclable in 2025/26, with 87% recyclable at kerbside, against a 100% target, and that its December 2025 goal of 100% sustainable paper and board in the UK was not met. The same report retires the voluntary packaging targets in favour of a 2035 circularity commitment that starts with packaging EPR and deposit return, and says Tesco takes full EPR responsibility for Own Brand while suppliers remain accountable for branded goods (page 22). Its supplier rules stay in force: the report describes the red, amber and green system as eight years old and backed by webinars and short training modules for suppliers (page 24).

## Recycled content: one per-pack aim and four portfolio goals

Recycled content is where the retailers' numbers look most alike and mean least alike. Tesco's figure is a per-pack aim for suppliers. The others are group averages by weight that no single supplier can meet alone (Exhibit 3).

Tesco's 2024 requirements ask suppliers to aim for a minimum of 30% recycled content where safe and feasible, and to use recycled content wherever safe for all materials. The document ties the level to UK law: plastic packaging with under 30% recycled content pays Plastic Packaging Tax ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)), quoted there at GBP 217.85 per tonne from April 2024. The rate is GBP 228.82 per tonne under section 45 of the Finance Act 2021 as substituted by the Finance Act 2026. SPI has not yet confirmed whether the 2026 list (PM08) restates the 30% aim, since the list itself covers materials and formats only.

Walmart's goals count post-consumer recycled (PCR) content only. Its playbook says PCR is preferred and asks suppliers to label recycled content with both the total percentage and the PCR percentage, which matters for any resin that blends post-industrial scrap. In FY2026 PCR rose to an estimated 12.0% of North America private-brand plastic packaging and 10.7% globally, up from 8.2% and 7.6% in FY2025 (FY2026 ESG page, 29 July 2026).

ALDI has two levels. ALDI UK's 18 June 2024 release restates an aim to "include 50% recycled content into its plastic packaging by 2025", while the ALDI SOUTH Group page lists 30% for own-brand plastic product packaging with no date. Published ALDI UK cases are mostly bottles: own-label soft drinks and water in England and Wales moved to 100% recycled PET, excluding cap and label, saving about 10,000 tonnes of virgin plastic a year (25 April 2024), and Specially Selected Hand Cooked crisp packs carry a minimum of 35% recycled content (18 June 2024).

Ahold Delhaize's Standards of Engagement ask every supplier to use recycled content where packaging is needed, and its group goal is 25% of own-brand primary plastic packaging weight by 2025. The 2024 statements report 15.7%, up from 14.8% in 2023 (page 104). The Q4 2025 summary report credits more recycled plastic for the 10.9% virgin plastic cut, but gives no recycled-content share, so SPI has not yet confirmed the 2025 figure.

In practice: Walmart.

Walmart announced its private-brand packaging goals on 26 February 2019; as now reported they are 20% PCR for North America and 17% globally, alongside 100% recyclable, reusable or industrially compostable packaging and a 15% virgin plastic cut. Its 28 February 2025 page said "we expect to fall short of achieving these goals by 2025", and the FY2026 page confirms all four short. The FY2026 report measures private-brand packaging by weight from supplier surveys or a web-based packaging compliance system, uses proxy data for suppliers that did not respond, and includes single-use and reusable bags in plastic (page 9). The FY2026 page states no post-2025 packaging goal.

## Recyclability: four definitions of the same word

Every retailer asks for recyclable packaging, and no two define it the same way (Exhibit 4). The differences decide whether a given pack counts.

Tesco's 2024 requirements say all packaging must be recyclable at kerbside or at the front of larger stores, the soft plastic collection points in large UK stores. That is why Tesco can report 99% recyclable but only 87% at kerbside. SPI calculation: 99 minus 87 leaves 12 points of UK Own Brand packaging by weight that relies on a front-of-store or other route. Those packs face the most pressure as PackUK's RAM ratings set fees ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)).

Walmart's playbook uses a 60% access test: a pack is recyclable only if it can be collected through an established programme available to at least 60% of the consumers or communities where it is sold. Its FY2026 report says goal progress is measured on the Ellen MacArthur Foundation definition, detailed in Walmart's Recycling Playbook. The playbook also tells suppliers not to rely on the Resin Identification Code and chasing arrows, and prefers How2Recycle labels in the US, which carried 92% of Walmart U.S. private-brand food and consumables supplier-reported sales in 2023 (28 February 2025 page).

ALDI's guidelines are the most technical of the four. They rate each component on a four-colour scale from best-case design to incompatible, set amber as the floor for acceptance and give an acceptance table by operating country. They count only mechanical recycling, so chemically recycled routes and composting do not make a pack recyclable under the guidelines. Version 4.0 also prepares for the EU Packaging and Packaging Waste Regulation (PPWR) grades A to C under [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/).

Ahold Delhaize's goal is the narrowest: plastic only, own-brand primary only, and "in practice and at scale". Its 2024 result was 33%, up from 28% in 2023 (page 104), against 100% for 2025. SPI has not yet confirmed a 2025 figure.

## Material bans: where the lists diverge

Material bans are the sharpest tool a retailer has, because they need no measurement: a pack either contains the material or it does not. Exhibit 6 sets out what each retailer prohibits or restricts, by name.

Tesco's red list is the longest. The 2024 edition (PM06, coded 010124) prohibits nine formats, from rigid black plastic, hi and mid cones, plastic straws and cutlery, glitter, composite drums and decorative aluminium laminates to paper or board laminated on both sides, and eight materials: compostable, PLA and biodegradable plastics, oxo-degradable plastics, polystyrene, PVC, PVdC, water-soluble plastics, MDF and waxed or siliconised paper. The 2026 edition (PM08) opens with the same items, adds packaging with batteries and replaces the 10% plastic-lamination limit for paper and board with a 15% non-paper content limit, defined as non-separable under EPR RAM. It marks six items as new, including fibre-based composites, shrink sleeves, RFID tagging on plastic and components under 40mm by 40mm; SPI has not yet confirmed the colour assigned to each of the six. Amber items, such as complex laminates, barrier papers, bio-based polymers and masterbatch containing carbon black, need approval from Tesco's packaging team.

ALDI's guidelines treat most of the same materials as incompatible with recycling. They say "ALDI does not accept the use of oxo-degradable or oxo-biodegradable materials in packaging", list PVC as not compatible and strictly to be avoided, treat carbon black as obstructive, and describe PVDC as not compatible in PE and PP formats. Polystyrene is accepted in some countries only.

Walmart's playbook names PVC, black plastic and biodegradable additives in petroleum-based plastics, plus priority chemicals, and asks for closures that match the parent material or separate easily. Ahold Delhaize's code names no material: its packaging clause asks suppliers to eliminate unnecessary plastic, reduce plastic, use recycled content and design for local recycling.

SPI analysis

The compostables split is the clearest case of retailers pulling in opposite directions. Tesco prohibits compostable and PLA plastics; ALDI's guidelines do not count them as recyclable, although the ALDI SOUTH Group page cites compostable sugarcane-pulp steak trays at ALDI Ireland. Walmart's and Ahold Delhaize's 2025 goals count compostable packaging as a success. A supplier that sells one compostable format into all four needs four different answers.

In practice: ALDI.

ALDI UK's product packaging page commits to "reduce, reuse, and recycle 100%" of its packaging and reports a plastic footprint of 124,940.15 tonnes for calendar 2023, covering own-label and branded primary, secondary and tertiary plastic sold in stores and online, and says 90% of that footprint comes from own-label primary plastic packaging, which it puts at 110,305.88 tonnes. The page says it will publish the data annually, but on 21 October 2026 it still showed 2023. Its 2025 goals, 50% recycled content (18 June 2024 release) and a 50% cut in plastic packaging (3 July 2024 release), have no published outcome, and the reduction baseline is not stated on the pages SPI read.

## Reduction: virgin plastic, total plastic or no number at all

Reduction targets are where the retailers' baselines and units differ most (Exhibit 7). Two count virgin plastic against a base year, one counts plastic packaging, ALDI SOUTH Group counts all material relative to sales, and Tesco now counts pieces and tonnes in case studies only.

Ahold Delhaize is the only one of the four with a met 2025 packaging goal that SPI has confirmed: virgin plastic in own-brand primary packaging was 10.9% below 2021 in 2025, against 5%, after 10.3% in 2024. Walmart moved the other way: private-brand virgin plastic was 4.12% above its FY2021 baseline in FY2026, against a goal of 15% below. Walmart notes that virgin plastic intensity per net sales dollar has fallen over three years, so the absolute rise reflects growth.

Tesco's reduction now runs case by case. The Sustainability Report 2026 cites over 18 million pieces of plastic removed from pre-packed avocados, almost five million from Finest and Organic berries, a trial of about 300,000 Cadbury Heroes paper tubs with Mondelez in October 2025, and Booker's Farm Fresh mushrooms moved to cardboard trays, forecast to save over 280 tonnes of plastic a year (page 24). Tesco also chairs the Reuse Packaging Partnership of nine grocers, whose Statement of Intent of July 2025 invites suppliers to work on reuse aimed at reducing single-use packaging by 2030.

## Reporting: the data each retailer wants

Reporting is the lever suppliers feel first, because it arrives as a form with a deadline. Exhibit 8 shows what each retailer asks for and where it goes.

Tesco's data rule is the most direct. Both the 2024 and 2026 lists state that packaging data must be provided to Valpak, and the 2024 document lists what it feeds: EPR payments, Plastic Packaging Tax payment and assurance, deposit return details, PRN payments and change tracking. The Central Europe version, valid from August 2024 and published in Czech, Hungarian and English, asks Own Brand suppliers for data to meet EPR obligations and for drink product details for deposit operators in Hungary and Slovakia.

Walmart collects packaging weights through its survey or compliance system and fills gaps with proxy estimates based on survey participation as a share of private-brand net sales (FY2026 report, page 9). How2Recycle data are not based on proxies. The playbook adds a softer ask: set goals, report progress publicly and quantify impact reductions.

In practice: Ahold Delhaize.

Version 5.0 of the Standards of Engagement took effect on 1 January 2026 and requires every supplier to comply with the standards and applicable laws, with own-brand suppliers also giving information and access on request. Its packaging clause, in section 6.5, urges four steps that mirror the group's Ellen MacArthur Foundation guided approach: eliminate, shift to reuse, shift to recyclable or compostable, and decouple from fossil feedstock. Results so far are mixed: virgin plastic 10.9% below 2021 in 2025, and 15.7% recycled content and 33% reusable, recyclable or compostable plastic in 2024. At bol, automated packaging machines deliver orders with 27% less packaging material (Annual Report 2025).

## A framework: rule strength by lever

Exhibit 1 is SPI's organising device for this piece. It sorts each retailer's ask on each of the five levers into one of four bands by the wording of the retailer's own document: a rule (must, prohibited, not accepted, strictly to be avoided), guidance (aim, urge, prefer, recommend), a portfolio goal (the retailer's own target, with no per-supplier ask), or none found.

Read across, the grid gives four retailer profiles. Tesco is a list enforcer: hard rules on recyclability, materials and data, and no numeric voluntary targets since the 2026 report. ALDI is a design-guideline setter: a technical rating scheme shared across ALDI Nord and ALDI SOUTH countries, with the highest recycled-content goal of the four (50% at ALDI UK) and the least published reporting. Walmart is a portfolio measurer: aggregate goals, a supplier survey and a playbook of preferences. Ahold Delhaize is a principles setter: a code that urges four steps, with portfolio goals for own-brand plastic.

SPI analysis

For a supplier, rules travel and goals do not. A red-listed material is out of a Tesco pack on the day the list applies, whatever Tesco's group results. A portfolio goal only becomes an ask when a buyer turns it into a specification, which is why Walmart's and Ahold Delhaize's shortfalls are likely to show up as pressure in category reviews rather than as written rules. The grid describes wording only; it does not score effort or results, and it is not a ranking.

The framework also shows a timeline effect (Exhibit 9). Most of the portfolio goals were set between 2019 and 2021 and fell due in 2025, while the supplier specifications have been updated since: Tesco in 2024 and 2026, ALDI in May 2022 and each April from 2023 to 2025, and Ahold Delhaize's code from 1 January 2026.

## Scenarios: what the asks mean in tonnes

Because the retailers' recycled-content levels range from 20% to 50%, the same supplier faces very different resin bills depending on the customer. Exhibit 10 sizes the gap for a simple case, in tonnes, with no currency.

The base case shows the spread. A range at 10% recycled content is 100 tonnes short of Walmart's North America level and 400 tonnes short of ALDI UK's. In the UK there is a second line in sterling only. SPI calculation: if the same 1,000 tonnes were UK-made or imported components below 30% recycled plastic, Plastic Packaging Tax at GBP 228.82 per tonne would be GBP 228,820 a year in each of the three starting cases, and GBP 0 once every component reaches 30% ([PR-GB-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-001/)). That cliff, not the retailer's guidance, is what makes 30% the working floor for UK packs.

Exhibit 11 asks a different question: at the pace each retailer last reported, how long until its own goal is reached?

In the base case, Walmart's PCR goals would be reached around FY2028 if the FY2026 gains of 3.8 and 3.1 points held. Ahold Delhaize's recycled-content goal would take about 10.3 years from 2024 at the 0.9-point gain of 2023 to 2024, and its plastic recyclability goal about 13.4 years at a 5-point gain. In the low case nothing moves; in the high case each goal is reached, which for the 2025 goals has not happened on any figure SPI has confirmed. **SPI analysis:**  law will close part of the gap faster than these paces. The PPWR sets 30% recycled content for single-use plastic beverage bottles from 2030 ([PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/)), and California's standard for redemption-value plastic bottles stepped to 25% in 2025 and reaches 50% in 2030 ([PR-US-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-009/)).

## Where the law now does the retailers' job

Tesco's 2026 report says outright that it is retiring voluntary packaging targets because EPR and deposit return legislation now apply. Exhibit 12 maps each lever to the statutory rule that now overlaps it in the markets these retailers serve, from the [SPI Regulation Tracker](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/).

The overlap changes what a retailer rule is for. In the UK, Tesco's red list and Valpak data feed PackUK fees and Plastic Packaging Tax; the list is now partly a cost control. In the EU, where Tesco Central Europe and Ahold Delhaize's European brands trade and Tesco Ireland and ALDI Ireland sell, the PPWR has applied since 12 August 2026, and ALDI's guidelines already write in its grades. In the US, Walmart's and Ahold Delhaize's banners face state EPR and recycled-content laws that set per-container floors the retailers' portfolio goals never did. For the EU detail see [the PPWR after August 2026](https://www.strategicpackaginginsights.com/insights/ppwr-after-august-2026/), and for recycled content against legal floors see [the recycled-content pledge gap](https://www.strategicpackaginginsights.com/insights/recycled-content-pledge-gap/). The SPI Packaging Buyers Database holds 148 packaging targets from 42 companies, including these four retailers' profiles.

## Industry reaction

> "We will now retire our voluntary targets, and focus on how we can work together across the food industry"

***Tesco** , retailer, [Sustainability Report 2026](https://www.tescoplc.com/media/yjmlhji0/tesco-sustainability-report-2026.pdf), page 23, reporting year 2025/26*

Tesco ties the change to new EPR and deposit return legislation and says it will continue to share progress in future reporting.

> "we expect to fall short of achieving these goals by 2025."

***Walmart** , retailer, [ESG: Waste and circular economy](https://corporate.walmart.com/content/corporate/en_us/purpose/esgreport/environmental/waste-circular-economy.html), 28 February 2025*

The FY2026 page of 29 July 2026 confirmed the shortfall on all four goals and named no successor goal.

> "However, ALDI’s expectation is to have all packaging designed at least light green rated."

***ALDI** , retailer, [International Recyclability Guidelines, Version 4.0](https://dm.emea.cms.aldi.cx/is/content/aldiprodeu/ALDI-International-Recyclability-Guidelines-V4pdf), April 2025*

The sentence before it sets amber-rated specifications as the minimum for acceptance, so light green is an expectation above the floor.

> "Ahold Delhaize also urges Supplier to 1) eliminate unnecessary plastic packaging 2) reduce the amount of plastic packaging used, 3) use recycled content where packaging is needed, and 4) design products that can be recycled locally."

***Ahold Delhaize** , retailer, [Standards of Engagement, version 5.0](https://media.aholddelhaize.com/media/uazm2xv2/ahold-delhaize-standards-of-engagement.pdf), effective 1 January 2026*

The word "urges" contrasts with the same document's "requires" for compliance with the standards and the law.

## The gaps in this comparison

**Unpublished results.**  SPI has not yet confirmed Ahold Delhaize's 2025 recycled-content and recyclability results, ALDI UK's outcomes for its 2025 goals, or a plastic footprint for ALDI UK after 2023. Tesco publishes no recycled-content figure for its Own Brand packaging.

**Colour coding.**  SPI read Tesco's 2026 list from its published layout; the colour of six items marked as new is not yet confirmed. Walmart's playbook is undated, so SPI treats it as current guidance only where the FY2026 report still points to the Recycling Playbook.

**Scope.**  Tesco's recyclability figures are UK only; Central Europe metrics are not reported. Walmart's and Ahold Delhaize's goals cover private and own brands only. ALDI's group goals and guidelines are shared across countries; ALDI UK's own goals are stated in press releases.

## What leaders should do now

1. **Packaging development leads at supplier brands, before the next range review:**  design each pack to Tesco's red list and ALDI's amber floor at once, since together they cover every material in Exhibit 6, and drop compostable plastics from any pack sold into Tesco.
2. **Procurement teams, by 31 March 2027:**  source recycled resin to reach 30% in every UK component before 1 April 2027, when pre-consumer scrap stops counting for Plastic Packaging Tax, and keep PCR separate from post-industrial content for Walmart reporting.
3. **Data and compliance teams, at each retailer's next data cycle:**  hold one component-level packaging record that can feed Valpak for Tesco, Walmart's survey or compliance system, and Ahold Delhaize's information requests, with weights, polymers and recycled content per component.
4. **Account managers for Walmart and Ahold Delhaize own brands, before 2027 contracts:**  ask buyers how the missed 2025 portfolio goals will turn into specifications, and offer redesigns quoted in the retailer's own unit (PCR share, virgin plastic tonnes against FY2021 or 2021).
5. **Sustainability teams, by 30 June 2027:**  map each pack's RAM rating for the UK and its likely PPWR grade for the EU, so that the 12-point kerbside gap Tesco reports and ALDI's light green expectation are tested on your own range.
6. **Drinks suppliers, by 1 October 2027:**  confirm deposit-return labelling and data for UK own-label and branded drinks with each retailer, and check that sleeves and labels meet Tesco's amber conditions for deposit-scope bottles.
7. **Commercial directors, at the next board budget:**  cost the Exhibit 10 resin gap for each retailer and the UK tax line in sterling, and decide which customers' levels the range will meet first.

## Questions for your board

- Which of our packs contain a material on Tesco's red list or below ALDI's amber floor, and what is the revenue at stake with each retailer?
- How much recycled resin do we need, in tonnes, to meet each retailer's stated level, and is it PCR?
- Can we supply packaging data at component level to Valpak, Walmart and Ahold Delhaize from one system?
- Which of our packs count as recyclable at Walmart or Ahold Delhaize but not at Tesco or ALDI, such as compostables?
- How will the retailers' missed 2025 goals show up in our 2027 specifications and tenders?
- Where does the law (UK tax, EPR fees, PPWR, US state rules) already set a harder floor than our customers do?

## What to watch

- **30 Nov 2026:**  PackUK plans to calculate confirmed Year 2 fees and issue the notice of liability by the end of November, putting a price on each RAM rating ([PR-GB-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-003/)).
- **31 Dec 2026:**  the PPWR implementing act on how recycled content is calculated and checked is due under Article 7(8) ([PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/)).
- **Feb 2027:**  Ahold Delhaize published its 2025 results on 11 February 2026; its 2026 results, if they follow the same timing, should show whether new packaging goals replace the 2025 set.
- **1 Apr 2027:**  pre-consumer scrap stops counting as recycled plastic for Plastic Packaging Tax, and the PackUK red multiplier rises to 1.6 ([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/)).
- **1 Oct 2027:**  UK deposit return starts for plastic and metal drinks containers ([PR-GB-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-kingdom/pr-gb-004/)).
- **1 Jan 2030:**  PPWR Annex V format restrictions and the 30% bottle recycled-content level apply, and California's bottle standard reaches 50% ([PR-EU-008](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-008/), [PR-EU-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-004/), [PR-US-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-009/)).
- **2035:**  the year of Tesco's single circularity commitment, which has no published metric or baseline yet.

## Methodology

- **Data used:**  SPI Packaging Buyers Database profiles for Tesco, Walmart, ALDI UK and Ahold Delhaize (written 14 October 2026), updated from each retailer's own supplier documents, codes, reports and releases, consulted 21 October 2026; SPI Regulation Tracker rule notes; legislation.gov.uk for the Plastic Packaging Tax rate.
- **Counting rules:**  every figure stays in the retailer's own measure, scope and year. Shares, gaps and paces are SPI calculations inside one retailer's series. No currency is added or compared; the only money figure is a GBP tax calculation.
- **Framework:**  the four bands in Exhibit 1 follow each document's wording (must, prohibited, not accepted or strictly to be avoided for a rule; aim, urge, prefer or recommend for guidance). Band choices are SPI's, and the grid is not a ranking.
- **Material coding:**  Exhibit 6 codes each retailer's named materials as 2, 1 or 0. Tesco codes follow its 2024 red list, which the 2026 list repeats.
- **Scenarios:**  Exhibit 10 assumes a 1,000-tonne range; Exhibit 11 extends each retailer's latest one-year change. Both are illustrations, not forecasts.
- **Cut-off:**  21 October 2026.
- **Limitations:**  supplier contracts and private retailer portals may carry terms that are not public. Some 2025 results are not yet published. This is business analysis, not legal advice; check obligations with counsel where they apply.

## Sources

1. Tesco PLC, Sustainability Report 2026, reporting year 2025/26 (pages 22 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 2026-10-21.
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