What's happening in the world of policy: July 2026
As it’s the summer holidays, it’s been quieter than usual, but that’s not to say nothing is happening in the world of policy! There has been a real packaging focus, with developments spanning pEPR, flexible plastic collections, PPWR and DRS, and a smattering of updates across other areas such as batteries and DPP, so let’s crack on…
UK
Packaging
The most important bit of news for this month is the appointment of a new Chair, and the new position of Deputy Chair, for the Packaging Scheme Forum - a collaboration of packaging schemes in the UK to work together with the regulators, Defra and PackUK, ensuring the smooth running of the machinery that is pEPR.
George Atkinson, Valpak, is heading up the forum as Chair
Michael Jennings, Beyondly, (that’s me) sat in the new position of Deputy Chair
I know RAM 2027 was published in July, but I’ve already spoken about that in last month’s update, so please head here to read more.
The 1 September resubmission deadline (also tackled last month) has caused a flurry of resubmissions. So hopefully the system is doing what it’s supposed to do and, come 1 September, all data will be as correct as possible and PackUK will be able to assess all submitted data and produce NoL and final fees by their current estimate of mid/late November.
Takeaway: Make sure you have systems in place to ensure your data is correct first time. Completing resubmissions later in the year adds on unseen costs to your compliance journey, not only from extra fees but also the manhours involved in combing through and recalculating your packaging data.
Mandatory flexible plastic collections across England, under Simpler Recycling, have been delayed now until 2030. Please note that this only affects mandatory roll out of flexible plastic collections and won’t affect those Local Authorities that are already collecting from kerbsides, nor will it affect Wales or Scotland, who have stated that they will still be aiming for the 31 March 2027 deadline for flexible plastic collections across those devolved nations.
The bottom line: We are delaying collections because there isn’t enough infrastructure, but what is this going to do for future investor confidence? Maybe with the renewed focus on domestic capacity, rather than relying on exports, along with the increasing cost of flexible plastics under the RAM (and future ETS expansion to cover EfW), there is more incentive now for funding to be channelled into this recycling stream?
Takeaway for the moment: Flexible plastics will be getting more expensive over the next couple of years, and we are hoping, due to the lack of incentive otherwise, we won’t see these higher costs lead to backsliding on the progress that has been made in terms of more recyclable flexible plastic formats in the interim…
PPWR in the UK? Due to implementation in Northern Ireland, the Government has suggested at a consultation on the ‘idea’ of adopting PPWR in early 2027. While not a consultation on actually adopting PPWR, but testing the waters, if this is anything like the EUBR consultations earlier in 2026, we can see potential alignment.
This is along with a government review of the EU’s [currently delayed] harmonised packaging labelling which will lay out a future roadmap for potential adoption and alignment across the whole of the UK.
Due to lead-times when developing packaging, especially around design, this is an area to keep an eye on, as a potential turnaround between the UK Government announcing their policy direction and mandatory harmonised labels in the UK could be tight, especially for those with large product or packaging portfolios.
pEPR adjacent: If we look at DRS, while seemingly plodding along and getting ready for go-live in 2027, there is increasing worry at the lack of DMO in Wales, and with apparently only a single applicant, Exchange for Change, many are wondering what the hold up is, and what this means for the integrity and interoperability of the Scheme with just over a year to go.
Batteries
Ignore my update from last month… we have had confirmation from Defra that they intend to consult on EUBR in the Autumn. This potentially means a busy 2027 as industry prepares for new regulations as early as 2028!
AOB
Under the AOB heading, but important nonetheless:
The Greenhouse Gas Protocol has partnered with ISO to create a single unified standard for corporate carbon accounting, with a consultation expected Q2 2027.
A consultation has opened to gather stakeholder views on Digital Product Passport Record policy in the UK. This links to EUBR in Northern Ireland and UK adoption, with certain battery formats requiring DPP in the EU in 2027, closely followed by other products such as textiles and toys.
EU
PPWR
PPWR is now live (as of 12 August 2026).
The Commission, after feedback, published v.2 of the FAQ document which updates and clarifies many areas, such as:
Enforcement: Light touch to avoid market disruption.
Manufacturer definition: For unbranded packaging, it all comes down to who specified the design of the packaging. For “off-the-shelf” packaging, this would usually be the company that creates the packaging.
Stock manufactured before go-live, but not placed on the market: You would have to gather the required manufacturer and batch ID information to retroactively label the packaging to be compliant, though this can be done on accompanying documents rather than on the packaging itself.
Harmonised labelling looks like it’ll now be delayed until Q1 2027 due to a backlog of secondary legislation that is stopping things being released or published on time.
The ECHA sent a list to various stakeholders, of SoC in packaging under Article 5(2), for consultation which will feed into future restrictions or DfR criteria.
EUBR
Another delayed piece of secondary legislation, the JRC have published a study on the harmonised rules for the calculation of recycled content in certain batteries formats. Considering this is only a JRC study and will need to be reviewed by the Commission before going out for public consultation and publication, this is, unsurprisingly, going to miss the 18 August 2026 deadline.
Work is also progressing on the list of products exempt from the general removability and replaceability requirements, with potential delays for certain products that will have a change of scope due to the need to amend product design. Work is still progressing on this though, but hopefully Parliament and Commission are reaching a consensus soon.
EUBR adjacent: Parliament adopted a report on the Commission’s proposed amendments to the CRMA, which was published on 2 July but withdrawn on 9 July. This therefore remains ongoing and could potentially become linked to the EUBR amendment discussions.
CSRD
A draft revised ESRS was published, reducing mandatory data points by >60%, alongside draft voluntary ESRS standards for SMEs. Both could be law by the end of 2026, so worth keeping an eye on even if you are only indirectly affected from other companies in your supply chain.
DPP
Alongside the exciting news that the UK is consulting on Digital Product Records, the implementation arrangements for the DPP registry were adopted by the Commission, laying the foundation for the DPP registry which is now live for testing; hopefully ready for batteries registration for February 2027, showing that secondary legislation can be published on time where absolutely required!
Looking ahead...
As we are deep into the summer holidays now, I am hoping that August will be a quiet month before everything kicks back off in September.
At Beyondly, we keep our stakeholders informed of key regulatory changes and emerging developments with timely insights and expert analysis.
Explore our Policy News hub for the latest environmental legislation updates, or get in touch with our friendly team at [email protected] or 01756 794951 to discuss how Beyondly can support your compliance and sustainability journey.
Glossary:
pEPR - Packaging Extended Producer Responsibility
RAM - Recyclability Assessment Methodology
NoL - Notice of Liabiility
PPWR - Packaging & Packaging Waste Regulation
EUBR - EU Batteries Regulation
DRS - Deposit Return Scheme (for drinks containers)
DMO - Deposit Management Organisation
DPP - Digital Product Passports
ECHA - European Chemicals Agency
SoC - Substances of Concern
JRC - Joint Research Centre
CRMA - Critical Raw Materials Act
ESRS - European Sustainability Reporting Standards
