# Two years after tethered caps became law, neither Nestlé nor Tesco reports on them in its 2026 packaging reporting, and the EU collects no data on whether they work

> Since 3 July 2024, plastic caps and lids on single-use beverage containers of up to 3 litres must stay attached in every EU Member State, with glass and metal containers and liquid medical foods left out; Nestlé and Tesco both carry the rule in their EU ranges but neither names it in its 2026 packaging reporting, Northern Ireland still has no law in force, and the Commission's evaluation due by 3 July 2027 is the first point at which the rule could change.

Publisher: Strategic Packaging Insights  
Published: 2026-10-29  
Last updated: 2026-10-29  
Page: https://www.strategicpackaginginsights.com/insights/tethered-caps-two-years-single-use-plastics-directive/

**Since 3 July 2024, plastic caps and lids on single-use beverage containers of up to 3 litres must stay attached in every EU Member State, with glass and metal containers and liquid medical foods left out; Nestlé and Tesco both carry the rule in their EU ranges but neither names it in its 2026 packaging reporting, Northern Ireland still has no law in force, and the Commission's evaluation due by 3 July 2027 is the first point at which the rule could change.**

Strategic Packaging Insights (SPI) read the Directive, the Commission's guidelines, the national texts in Germany, Austria, Spain and Ireland, and both companies' 2025 and 2026 reports, alongside rule [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/) in the SPI Regulation Tracker, which holds 79 packaging rules. The finding is that a rule which reaches every plastic drinks bottle and carton up to 3 litres in the EU has produced almost no published numbers: no EU compliance reporting, no enforcement case SPI has found, and no tethered cap metric from either company.

## Executive summary

Article 6(1) of the Single-Use Plastics (SUP) Directive, (EU) 2019/904, has applied since 3 July 2024. It allows beverage containers listed in Part C of the Annex, those of up to 3 litres including composite cartons, to be placed on the market with plastic caps or lids only if those caps and lids stay attached during the product's intended use. Glass and metal containers are outside Part C even when their caps are plastic, metal caps with plastic seals do not count as plastic, and containers for liquid food for special medical purposes are excluded. A closure that conforms to EN 17665:2022+A1:2023, cited by Implementing Decision (EU) 2023/1060 on 1 June 2023, is presumed to comply.

Two years on, the rule is settled on the shelf but almost invisible in the data. Article 13 of the Directive asks Member States to report on consumption reduction, separate collection and recycled content, but not on Part C caps. The SPI rule note for [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/) records no enforcement case in the EU sources it read, and SPI has found none since. Neither Nestlé's September 2026 packaging strategy nor Tesco's Sustainability Report 2026 uses the word tethered.

The national texts differ where it costs money. Germany treats a breach as an administrative offence with a fine of up to EUR 100,000; Ireland makes it a criminal offence with up to EUR 500,000 or three years on indictment; Austria lets stock placed on the market before 3 July 2024 run down. Northern Ireland, where Article 6 applies under the Windsor Framework, still has no instrument in force, and its environment department expects one in 2027.

For the two companies, the exposure is moving. Nestlé's main in-scope range, its bottled waters, is excluded from its 2030 virgin plastic target and is heading into Peranel, a 50:50 joint venture with Platinum Equity expected to close in the first half of 2027. Tesco's in-scope range is its own-label drinks in Ireland, Czechia, Hungary and Slovakia, where it reports deposit returns but not closures; its UK range, its largest, is outside the rule.

For leaders, three moves matter: keep a closure register and EN 17665 evidence per SKU, because that is the first document an inspector will ask for; plan Northern Ireland as an EU-rule market from 2027; and prepare a response for the 2027 evaluation, the first point at which Article 6 could be reopened.

## Key findings

1. Article 6(1) has applied for 848 days, from 3 July 2024 to 29 October 2026 (Directive (EU) 2019/904, Article 17(1)), to beverage containers of up to 3 litres with plastic caps or lids, including composite cartons and pouches (Commission guidelines, 7 June 2021).
2. Article 13 of the Directive sets no reporting duty for Part C caps, so no EU dataset on compliance exists; the evaluation due by 3 July 2027 drew a public survey that closed on 17 March 2026 (European Commission, 23 December 2025).
3. Germany fines a breach as an administrative offence of up to EUR 100,000 (EWKKennzV section 5 with KrWG section 69(3)); Ireland allows up to EUR 500,000 or three years on indictment (S.I. No. 516/2021, regulation 13(2)).
4. Northern Ireland must transpose Articles 2 to 7, 14 and 17 of the Directive under the Windsor Framework, and expects its legislation in force in 2027 (DAERA, last modified 14 April 2026).
5. A German consumer study rated tethered caps 3.8 out of 10 overall and 2.8 among people with reduced dexterity, and asked for EN 17665 to be revised (DIN Consumer Council, 14 November 2024).
6. Nestlé excludes Nestlé Waters and Premium Beverages from its 2030 virgin plastic baseline of 611 kt, and has agreed to move that business into Peranel at an enterprise value of EUR 4.9 billion, closing expected in the first half of 2027 (Nestlé, September and July 2026).
7. Tesco reports 247 million containers returned through 345 reverse vending machines in 191 Irish stores in the second year of Re-turn, a 104% return rate, but no closure metric (Tesco Sustainability Report 2026).

## What the rule covers, and what it leaves out

Part C of the Directive's Annex is short. It covers beverage containers with a capacity of up to three litres, meaning receptacles used to contain liquid, such as bottles and composite beverage packaging, together with their caps and lids. It then leaves out two groups: glass or metal beverage containers whose caps and lids are plastic, and containers intended and used for food for special medical purposes in liquid form, as defined in Regulation (EU) No 609/2013 (EUR-Lex). Article 6(2) adds that metal caps or lids with plastic seals are not considered plastic for the purposes of the Article.

The Commission's guidelines of 7 June 2021 fill in the edges (Exhibit 2). Containers above 3 litres fall outside the Directive's scope for this rule. Beverage cartons are composite beverage packaging and are expressly included, and pouches that are fully plastic or carry a plastic layer, up to three litres, are listed as beverage containers. Milk counts as a beverage; soups, yoghurts that are not drinkable, fruit purées, syrups, cordials and vinegar do not (guidelines, section 4.5.1).

The guidelines also separate three kinds of closure. Caps are closures fitted onto beverage containers or bottles, typically screw or hinged snap types. Lids are plastic, or composite material with plastic film, sealed onto a container and not replaceable once removed. Covers sit on cups and can be refitted, but generally do not seal (Exhibit 3). Only caps and lids on Part C containers must stay attached.

SPI analysis

For a brand owner, the hard cases are not bottles but cartons and pouches, because packaging teams often file them under paper or flexibles. The SPI Ledger piece on [beverage carton EPR fees](https://www.strategicpackaginginsights.com/insights/beverage-carton-epr-fees-austria-benelux-portugal/) shows how the tethered cap's plastic weight is charged inside carton fee lines; the compliance duty sits here, in Part C.

## The standard: EN 17665 and the presumption of conformity

Article 6(3) required the Commission to ask the European standardisation bodies for harmonised standards by 3 October 2019, covering the strength, reliability and safety of closures, including for carbonated drinks. Article 6(4) then presumes that a container meeting those standards complies with Article 6(1). The SPI rule note for [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/) records the standardisation request as Implementing Decision C(2020) 7244 of 27 October 2020.

Implementing Decision (EU) 2023/1060, adopted on 30 May 2023 and in force on its publication on 1 June 2023 (OJ L 142, p. 34), cites EN 17665:2022+A1:2023, the packaging standard on test methods and requirements to show that plastic caps and lids remain attached to beverage containers. Its recital 2 frames the scope as certain single-use plastic beverage containers of up to three litres with plastic caps and lids. Austria's business service portal, updated on 1 January 2026, points firms to the national edition, ÖNORM EN 17665, and the chamber of commerce in Upper Austria noted on 4 August 2023 that meeting the standard creates the presumption of conformity.

The presumption matters because it changes who carries the burden. A filler that holds an EN 17665 test report for each closure and neck finish starts from a presumption of compliance; one that does not has to argue from first principles that its design stays attached in intended use. The SPI rule note for [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/) makes the same point: the test report is the first document an inspector can ask for.

The standard is not frozen. The DIN Consumer Council's study of 14 November 2024 recommends revising DIN EN 17665 on opening strength, dexterity, cognition, opening mechanisms and force and handling, drawing on DIN EN ISO 17480 on accessible packaging, and making consumer target-group testing mandatory. SPI has not yet confirmed any CEN work item to revise EN 17665.

## How four Member States and Northern Ireland wrote it into law

Article 17(1) required Member States to apply Article 6(1) from 3 July 2024, and Article 14 leaves the penalties to them, as long as they are effective, proportionate and dissuasive (EUR-Lex). The four national texts in SPI's data, and the Northern Ireland position, show how far that leaves room to differ (Exhibit 4).

**Germany.**  Section 3(1) of the Einwegkunststoffkennzeichnungsverordnung (EWKKennzV), made on 24 June 2021, lets beverage containers of up to 3.0 litres whose caps or lids are wholly or partly plastic be placed on the market from 3 July 2024 only if the closure stays attached during intended use, and presumes compliance for containers built to the harmonised standards (gesetze-im-internet.de). Section 3(2) carries the three exemptions. Section 5 makes placing a non-conforming container on the market, intentionally or negligently, an administrative offence under section 69(1) number 8 of the Kreislaufwirtschaftsgesetz, and section 69(3) sets the ceiling at EUR 100,000. The SPI jurisdiction note for Germany records that the federal environment agency runs the single-use plastics fund, while offences under packaging law are pursued by each Land.

**Austria.**  The federal business service portal places the duty in section 4(6) of the Verpackungsverordnung 2014 and repeats the three exemptions. It adds one practical rule the Directive does not spell out: containers first placed on the Austrian market before 3 July 2024 without tethered caps may still be supplied after that date. SPI has not yet confirmed whether the June 2026 changes that the SPI Austria note records, made as the PPWR took effect, renumbered that section, or the penalty that applies.

**Spain.**  Ley 7/2022 transposes the rule in Article 57, titled design requirements for plastic beverage containers. Paragraph 1 applies the attachment duty from 3 July 2024 to Part C products of Annex IV and treats metal caps and lids with plastic seals as not plastic; the same article carries the PET recycled content floors. SPI has not yet confirmed which infringement class in Article 108 a breach falls into.

**Ireland.**  Regulation 6(1) of S.I. No. 516/2021, made on 8 October 2021, bars producers from placing Part C containers on the market from 3 July 2024 unless the cap or lid is designed and made to stay attached during use, with a presumption for harmonised standards in regulation 6(2) (Irish Statute Book). Regulation 13(2) makes a breach an offence carrying, on summary conviction, a class A fine or up to 12 months' imprisonment or both, and on indictment a fine of up to EUR 500,000 or up to three years or both. Regulation 12(1) shares enforcement between the Environmental Protection Agency and local authorities. The government's guidance, last updated on 27 January 2026, says the rule covers bottles, cartons and pouches.

**Northern Ireland.**  The Department of Agriculture, Environment and Rural Affairs (DAERA) says, on a page first published on 22 May 2024 and last modified on 14 April 2026, that the Windsor Framework requires it to transpose Articles 2 to 7, 14 and 17 of the Directive, which takes in Article 6. The page lists the changes as to be confirmed and expects legislation in force in 2027. Great Britain has no tethered cap rule among the UK rules in the SPI Regulation Tracker, and the SPI Ledger piece on [England's and Wales's single-use plastic bans](https://www.strategicpackaginginsights.com/insights/england-wales-single-use-plastic-bans-packaging/) covers what GB does ban.

SPI analysis

A supplier that sells the same bottle in Dublin, Belfast and Manchester today faces a requirement with criminal sanctions, a requirement with no law behind it yet, and no requirement at all. From 2027 the first two should converge.

## Enforcement: a rule with no published scorecard

The Directive builds no feedback loop for Article 6. Article 13(1), as SPI reads it on EUR-Lex, asks Member States to report on Part A consumption reduction, Part F separate collection, fishing gear, Part F recycled content and Part E Section III products. Part C caps are not on the list. Article 15 requires the Commission to evaluate the whole Directive by 3 July 2027 and report to Parliament, Council and the European Economic and Social Committee, with a legislative proposal if appropriate.

The Commission opened that evaluation on 23 December 2025 with a call for evidence and a public survey that closed on 17 March 2026 (DG ENV). Its news item says the findings will help decide whether new rules are needed, and the DG ENV topic page lists product design rules such as tethered caps among the measures Member States apply. Neither page reports any figure on cap compliance or cap litter since 2024.

SPI's own record matches. The [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/) rule note, last checked on 14 October 2026, records no enforcement case on tethered caps in the EU sources read for the rule, and SPI has found no published German, Austrian, Spanish or Irish decision since. That does not mean nobody inspects; it means a buyer cannot price the risk from case law.

SPI analysis

The absence of reporting cuts both ways. Fillers face little visible enforcement pressure, but the evaluation will also lack evidence that the rule cut litter, which is the evidence a defender of the rule would need. Businesses that hold their own data on returns with caps attached will have something the Commission does not.

## Consumer reaction, in official sources

The official record on consumer reaction is small but consistent. The Commission's Representation in Spain published a piece on 22 October 2024 framed as dispelling myths about attached caps. It explains the change as a duty under the SUP Directive, says caps are usually made of PET or polypropylene and are easier to recover when attached, and states that plastic caps are found two to three times more often than bottles in marine litter. The Commission's own news item of 14 August 2024 explains the change in one line, quoted in the reaction section below.

The DIN Consumer Council's study, commissioned from a research consultancy and dated 14 November 2024, tested 13 tethered cap designs across six cap types with 30 consumers in Berlin, in five groups: children aged 6 to 9, people with reduced dexterity, people over 70, people with visual impairment and people without impairments (Exhibit 5). It is qualitative and small, and it says so.

The study found drinking problems with sports caps and lasso caps, where the cap hit the face or nose; worst re-closing with heli caps; easy re-closing with snap caps; spills linked to thin bottle walls and hard-to-open caps; and consumers who simply snapped the tether off sports caps. Participants saw little environmental benefit, and the positive comments were mainly that the cap can no longer be lost. Germany's consumer advice centres describe the same pattern in plain terms: shoppers tugging at caps they did not know were fixed, and a partly torn-off piece left in the hand. Their page adds that more than 40 loose caps were found on about 100 metres of North Sea beach in surveys, and that some makers print opening instructions on the cap.

SPI analysis

The evidence points at design quality, not at the rule. The best-rated design in the DIN study scored 6.8 against 3.8 overall, so the spread between closures is wider than the spread between people. For a brand owner, closure choice is a consumer experience decision as well as a compliance one, and accessibility is the part most likely to be raised in the 2027 evaluation.

## A framework: four closure regimes

The rule now sorts a drinks range into four regimes, set by where the product is sold and what it is made of (Exhibit 6). The regimes come from Part C, the national texts in Exhibit 4 and the SPI tracker rules, and each calls for a different action from the two companies in this piece.

**Regime A, in force.**  The work is evidence: a closure register by SKU, container material, volume and tether design, with an EN 17665 report per closure and neck finish, which the [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/) compliance steps list. The risk is the long tail, such as a seasonal carton or a pouch drink, not the core PET line.

**Regime B, required without a law.**  Northern Ireland is the one market where a rule is certain but its text and penalties are not. A business that ships GB-specification drinks there will need to change them once DAERA's instrument applies.

**Regime C, outside.**  Great Britain is a choice, not a duty. A brand can keep one closure across GB and the EU, or run two. Neither company has published which it does, as Exhibits 8 and 9 show.

**Regime D, exempt by format.**  Format exemptions are the legal route around the rule: a glass bottle, a can, a 5 litre pack or a metal crown. Each moves cost elsewhere, such as weight in glass or the EPR fee lines covered in the SPI Ledger pieces on glass and aluminium.

## Where the PPWR meets Article 6

The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has applied since 12 August 2026, and the SPI Ledger's [PPWR after August 2026](https://www.strategicpackaginginsights.com/insights/ppwr-after-august-2026/) covers its general duties. For caps, the question is whether it changes Article 6. On the texts SPI has read, it does not (Exhibit 7).

Commission Notice C/2026/3084, the PPWR guidance published on 10 June 2026, sets the order of precedence in section 16. Article 67(1)(a) of the PPWR, as the Notice summarises it, lets the SUP Directive prevail where the two conflict, with an exception in Article 67(1)(b) for the single-use plastic formats in Annex V, point 3. Annex V restrictions are covered in the SPI Ledger piece on [PPWR 2030 format restrictions](https://www.strategicpackaginginsights.com/insights/ppwr-2030-format-restrictions/) and are not repeated here; none of them is a beverage closure. The Notice also says that the PPWR definition of composite packaging should not exempt single-use packaging partly made of plastic, which keeps cartons in Part C.

The links are practical rather than legal. The PPWR deposit duty in Article 50, a 90% separate collection rate for single-use plastic bottles up to three litres and metal beverage containers by 1 January 2029, puts the attached cap into the same return stream as the bottle. Implementing Decision (EU) 2026/1425 of 30 June 2026, in force from 23 July 2026, defines a beverage bottle as including its cap, lid, label and sleeve, if any (Article 1(3) of the adopted act, C(2026) 4381), and counts only the plastic parts, so the cap's plastic sits in the bottle's weight for the recycled content calculation and a heavier tethered cap with no recycled content lowers the reported share.

SPI analysis

The tethered cap has become part of three PPWR calculations it was not designed for: deposit returns, recycled content and design for recycling grades. Closure choice made in 2023 for Article 6 now affects reported numbers under a different law.

## Nestlé: a closure rulebook, but the bottles are leaving

Nestlé does not report on tethered caps. Its Packaging Sustainability Strategy of September 2026 and its public Rules of Packaging Sustainability, also updated in September 2026, do not use the word tethered, and the strategy has no section on caps, closures or lids (Exhibit 8). What Nestlé does publish is a general closure rule and a set of plastic metrics.

The closure rule sits in chapter 1b of the Rules, on rigid plastics. It tells packaging teams to make sure material choice, liners and seals in closures do not cause problems in recycling, to phase out silicone in PE or PP closures and to use mono PP or mono PE. The Negative List names liners for metal closures among PVC uses to remove. Those rules apply to a tethered cap as to any other, but they say nothing about attachment, EN 17665 or Article 6.

In practice: Nestlé.

The SPI Packaging Buyers Database records Nestlé entities in Germany, France, Ireland and Austria inside Zone Europe, Germany at CHF 1,921 million of 2025 sales, and notes that Nestlé Waters' bottles carry [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/) and [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/) while the business stays consolidated. On 23 July 2026 Nestlé announced Peranel, a 50:50 joint venture with Platinum Equity for its waters and premium beverages business, naming S.Pellegrino, Source Perrier, Acqua Panna and Nestlé Pure Life among more than 30 brands in 120 countries, with about EUR 3.0 billion of cash to Nestlé at closing in the first half of 2027. The September 2026 strategy already excludes that business from the 2030 target. **SPI analysis:**  once Peranel closes, the PET water bottles that carry most of Nestlé's Article 6 exposure will be reported, if at all, by the joint venture; Nestlé's remaining EU exposure will be ready-to-drink and dairy lines, whose closures SPI has not yet confirmed.

Two of the brands named in the release, S.Pellegrino and Perrier, are widely sold in glass and cans, which Part C excludes. SPI has not yet confirmed the share of Peranel's EU volume in PET, so the size of the tethered cap exposure that moves with it cannot be stated.

## Tesco: deposit data, cap removal, and the PPWR in view

Tesco does not report on tethered caps either. Its Sustainability Report 2026 covers packaging on pages 23 to 25, and the terms caps, lids and tethered do not appear there; the nearest reference is to seals on milk bottles and corks in wine bottles as components that remain hard to recycle but are needed for shelf life or safety (Exhibit 9).

Two items in Exhibit 9 are closure decisions, though neither is described as a response to Article 6. Removing more than 12 million caps from juice cartons takes the carton out of the tethering question altogether, since a carton with no plastic cap has nothing to attach. Changing coloured milk caps to clear ones is a recyclability choice for HDPE milk bottles; milk is a beverage under the Commission guidelines, so the same bottles sold in Ireland need attached caps, while in Great Britain they do not. SPI has not yet confirmed which markets the juice carton change covered.

In practice: Tesco Ireland.

Tesco reports almost 8.4 million customers returning 247 million containers in the second year of Re-turn, an average of 29 containers per customer visit, and a 104% return rate because customers also bring back containers bought elsewhere. Re-turn's consumer guide says a bottle can be returned with or without its cap but that returning it with the cap is preferred, and sets deposits of 15 cent for containers of 150 ml to 500 ml and 25 cent for those above 500 ml up to 3 litres. **SPI analysis:**  a tethered cap makes the preferred return the default one. Tesco's machines are therefore the place where Article 6 and the PPWR deposit duty meet, and the one place where Tesco could measure caps returned with bottles; it does not publish that figure.

The SPI Packaging Buyers Database records Tesco's Republic of Ireland sales at GBP 3,239 million and Central Europe at GBP 4,490 million in 2025/26, against GBP 49,819 million in the UK. By SPI's calculation, the markets where Article 6 applies to Tesco today account for GBP 7,729 million, about 13% of the GBP 57,548 million across the three segments, all in GBP. The rule bites on the smaller part of Tesco's business, which helps explain why its UK-weighted reporting does not mention it.

## Scenarios: what a non-conforming range could cost

SPI ran three simple cases for a filler found placing non-conforming containers on the German and Irish markets, using only the maximum fines in the national texts (Exhibit 11). The number of offences is an SPI assumption; an authority decides how many breaches it pursues, and a court sets the fine. All figures are EUR, and the two countries are shown side by side, not added.

**SPI calculation:**  the ratio between the two ceilings is five to one, in EUR, so the same closure fault is priced very differently across two markets that sit under one Directive. The low case also shows that the fine is rarely the main cost. A non-conforming closure cannot be fixed on the shelf; the realistic cost is withdrawing and re-filling stock, which no text prices and which SPI has not modelled.

## What each part of the chain must do

The duty falls on whoever places the container on the market, but the evidence has to come from closure makers (Exhibit 12).

SPI analysis

The Peranel deal is a reminder that compliance files move with assets. A buyer of a drinks business takes on its closures, its test reports and its recycled content data, and with Decision (EU) 2026/1425 those now interact.

## Industry reaction

> "Since July 3, single-use plastic bottles sold in the EU must come with their caps or lids attached."

***European Commission** , [Less plastic waste means cleaner beaches](https://commission.europa.eu/news-and-media/news/less-plastic-waste-means-cleaner-beaches-2024-08-14_en), 14 August 2024*

The same item describes the change as one of the outcomes of the EU law on single-use plastics, alongside design requirements for other products.

> "Other obligations in the Directive mean that since 3 July 2024, beverage containers (bottles, cartons, pouches) up to 3 litres cannot be placed on the Irish market unless the cap is attached to the main part of the container (that is, tethered caps)."
>
>
>
> **Department of Climate, Energy and the Environment** , Government of Ireland, [Single-use plastics](https://www.gov.ie/en/department-of-climate-energy-and-the-environment/publications/single-use-plastics/), updated 27 January 2026
>
>
>
> "Work on legislation is progressing, currently expected to be in force in 2027."
>
>
>
> **Department of Agriculture, Environment and Rural Affairs** , Northern Ireland, [Single Use Plastic Directive](https://www.daera-ni.gov.uk/articles/single-use-plastic-directive), last modified 14 April 2026
>
>
>
> "For closures, ENSURE material choice, liners and seals are not problematic for recycling"

***Nestlé** , packaging policy, [The Rules of Packaging Sustainability](https://www.nestle.com/sites/default/files/2025-06/rules-packaging-sustainability.pdf), September 2026*

SPI analysis

The four statements show where the rule stands. The Commission and Ireland describe it as settled, Northern Ireland as pending, and the company rulebook treats closures as a recycling question, not an attachment one.

## What leaders should do now

1. **Packaging compliance leads at fillers, by 31 December 2026:**  complete a closure register for every EU SKU up to 3 litres, with container material, volume, closure type and EN 17665 report, and flag cartons and pouches separately.
2. **Retail own-label teams, by 31 March 2027:**  confirm which own-label drinks are sold in Northern Ireland and specify EU-style tethered closures for them ahead of DAERA's 2027 instrument.
3. **Regulatory affairs teams, by the Commission's 2027 evaluation:**  prepare evidence on cap returns, consumer complaints and accessibility for the evaluation due by 3 July 2027, since no Member State reports on Part C.
4. **Closure buyers, at the next tender:**  ask suppliers for part weights and recycled share per cap, because Decision (EU) 2026/1425 counts the cap in the bottle's recycled content.
5. **Deposit and returns teams at retailers, during 2027:**  measure the share of containers returned with caps attached at reverse vending machines, the one figure that would show the rule working.
6. **Corporate development teams in drinks deals, before closing:**  include closure files, test reports and recycled content data in the transfer schedule, as any business moving into a joint venture such as Peranel will need them.
7. **Product designers, in 2027 briefs:**  test new tethered designs with users who have reduced dexterity, following the DIN Consumer Council's call for target-group testing.

## Questions for your board

- Do we hold an EN 17665 test report for every closure we place on an EU market, and could we produce it in a day?
- Which of our drinks are sold in Northern Ireland, and what changes when its law applies in 2027?
- Do we run one closure across Great Britain and the EU, or two, and what does each choice cost?
- What share of our returned bottles come back with caps attached, and do we measure it?
- How does our tethered cap's weight and recycled content change the recycled share we report?
- If the 2027 evaluation reopened Article 6, what evidence would we bring?

## What to watch

- **2027:**  Northern Ireland's tethered cap legislation is expected in force (DAERA).
- **First half of 2027:**  Peranel is expected to close, moving Nestlé's waters and premium beverages business into a 50:50 joint venture (Nestlé, 23 July 2026).
- **3 Jul 2027:**  the Commission's evaluation of the SUP Directive is due under Article 15, with a legislative proposal if appropriate.
- **1 Jan 2029:**  Member States must reach 90% separate collection of single-use plastic bottles up to 3 litres and metal beverage containers under PPWR Article 50.
- **1 Jan 2030:**  the Directive's 30% recycled content floor for Part F bottles applies, with caps counted in the bottle's plastic weight ([PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/)).
- **No date set:**  any revision of EN 17665 following the DIN Consumer Council's recommendations.

## Methodology

- **Data used:**  SPI Regulation Tracker rule [PR-EU-015](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-015/), the [PR-EU-016](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-016/) note, and the Austria, Germany, Spain and Ireland jurisdiction notes; SPI Packaging Buyers Database profiles for Nestlé and Tesco, all as of 14 October 2026. Official texts on EUR-Lex, gesetze-im-internet.de, the Austrian business service portal, BOE and the Irish Statute Book; Commission, Irish and Northern Ireland government pages; the DIN Consumer Council study; Nestlé's and Tesco's own reports. Sources consulted on 29 October 2026.
- **Counting rules:**  a container is in scope where Part C and the national text apply on 29 October 2026. "Not reported" means SPI found no figure or mention in the company documents listed in Exhibits 8 and 9; for Nestlé's Non-Financial Statement 2025, SPI read the summary pages and did not find a tethered cap reference.
- **Calculations:**  day counts are calendar days. Fine scenarios multiply the statutory maximums by an assumed number of offences, in EUR only, and do not add the two countries. Tesco market shares divide GBP segment sales from the SPI profile; no currency is converted.
- **Cut-off:**  29 October 2026.
- **Limitations:**  penalties in Austria and Spain, the current Austrian section number, the market of Tesco's juice carton change, and the PET share of Peranel's EU volume are not confirmed. The DIN study is qualitative, with 30 participants. This is not legal advice; check with counsel for a specific product.

## Sources

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