pEPR Update: Fibre-based composite reporting
Member actions: Affects current submission period (H1 2025 data)
Key takeaways: Fibre-based composite (FBC) and paper or board definitions amended to match incoming amended SI
On 7 July 2025, the four UK nations published a regulatory position statement (RPS) allowing producers to use the upcoming amended definitions of FBC and paper or board in the current submission period (packaging supplied between 1 January and 30 June 2025).
While this announcement doesn’t change your legal obligation to use the current definition of FBC, the regulators will not be taking enforcement action against those who choose to use the amended definition.
Definitions
Fibre-based composite
- is made of paperboard or paper fibres, with one or more layers of plastic, and which may also have layers of other materials, to form a single unit that cannot be separated by hand,
- is not in the paper or board packaging category.
Paper or board
- if it can be evidenced that the layer(s) or plastic are not more than 5% of the material by weight,
- then the packaging material should be reported as paper or board.
Further notes
This statement brings the definition of FBC and paper or board in line with the RAM threshold and allows producers to use the definition in the upcoming amended regulations, without having to resubmit any data for their H1 and H2 submissions to match under the amendments, also saving a significant administrative burden on the regulations that resubmissions would bring.
Links
Scotland [TBC]