What's happening in the world of policy: October 2026
It’s the end of October. The Autumn Budget has been delivered. The nights are drawing in. And still the policy machine grinds forwards!
Before we get into the weeds, a quick roundup of some of updates that caught my eye this month:
Will the EU’s Circular Economy Act be announced on 11 November?
Omnibus amendments to Corporate Sustainability Reporting Directive (CSRD) revised and voluntary standards have been published, along with amendments to goods covered by European Union Deforestation Regulation (EUDR) to be out of scope until the end of 2027.
The EU’s Battery Regulation (EUBR) is now in force in Northern Ireland, with UK consultation for Great Britain still due this Autumn.
And the EU’s EmpCo Directive is now live in the EU, setting new standards for green claims and unfair commercial practices for those supplying goods into the EU and Northern Ireland.
UK Packaging
On Friday 9 October, the Government stepped in to announce much needed intervention to the PRN system. As this is an important topic for many producers, please see full details on our recent news story.
Action for you: Read through our news story and make sure you are up to date with our latest communications on PRNs to ensure your finance team understand what this RPS means for your business.
Meanwhile, the Packaging Scheme Forum (PSF) has launched their ‘Keep Packaging Recycling Working’ campaign responding to a push from certain groups to scrap, rather than improve, the PRN system. They have warned that abolishing PRNs without considering a working replacement would be a “reckless gamble with Britain’s recycling industry”.
We finally have a look at what activities UK Packaging PRO will be taking from PackUK with their publication on “a new approach to RAM updates”. Please check out our latest news story exploring what this means for you, how to get involved, and other considerations on how this will work in practice.
Action for you: If you have recyclability evidence that you wish to present to help with future RAM development, make sure you submit to the PRO before the end of the year, and please ensure that your evidence is complete and evidenced.
DRS
We’ve just passed T-1 year to go until the UK’s Deposit Return Scheme (DRS) for drinks containers goes live and, while Exchange for Change (EfC) are busy laying the foundations for a strong and effective scheme, registration is now open for producers and retailer return points!
Action for you: I encourage those who need to register to do so as soon as possible during this simpler Phase 1, before reading through future registration requirements and containers specifications before Phase 2 in January 2027.
With the deposit set at 20p, producer fees have now been introduced, set at 0p until the end of 2028, raising to 0.6p per unit for metal and 2.3p for PET containers for 2029-2032.
In the meantime, the system will be funded by unclaimed deposits, which is interesting on two fronts: With the system launching in October 2027, and return rates needing to hit 70% for 2028, will there be enough money unclaimed to fund the system… equally… will we see EfC hitting that collection target for 2028?
This transitions nicely into the update on transitional arrangements for filled and unfilled containers before 1 October 2027. With filled containers made before this date now out of scope of DRS, and sell through to April 2028, are we going to see greater confusion among consumers? Already having to grapple with a new system to recycle their drinks containers, they will now have to sort through their empty cans and bottles to find out which can be recycled at home and which will need to be returned via a Reverse Vending Machine (RVM). This could mean more deposits are lost through containers going to kerbside, alongside frustration for consumers who make the effort to return their containers to a RVM, only to be rejected due to being out of scope (I do hope there is a handy recycling bin nearby to stop the litter that DRS is supposed to prevent!)
Action for you: Speak to your supply chain to ensure you understand how the transitional arrangements affect you and your customers, to avoid confusion of which drinks containers you can and cannot supply after 1 October 2027.
PPWR
One of the linchpins of packaging and waste reforms in the UK and the EU, in my mind, is harmonised labelling.
You can overhaul reporting requirements for producers, you can imbed Extended Producer Responsibility (EPR), you can invest and update recycling infrastructure and make packaging more recyclable… but at the end of the day, if the consumer doesn’t know, confidently, what to recycle, how, and where, the changes are for naught.
Harmonised labelling is due to simplify packaging recyclability labelling, and harmonise it across different countries or areas, so that consumers know exactly what to recycle. And the EU has been working on this for a while now (as we have reported on previously), but recently the timeline has started slipping!
Originally due to come into force from 12 August 2028 with legislation published two years beforehand, we have now passed the August 2026 publication date, with a new date set for Q4 2026… then Q1 2027… and now Q2 2027…
And this has a huge effect on businesses in the UK too, as it is expected that, once published, the UK Government will look at adopting these labels across the whole of the UK due to PPWR coverage in Northern Ireland.
I am still hopeful that we will see draft regulations before 2026 is out, with adoption mid-2027, to give both UK and EU companies plenty of time to assess their packaging portfolios and prepare accordingly.
Action for you: In the meantime, please acquaint yourselves with the possibilities I’ve outlined in the JRC proposal linked above, and start those conversations now with your finance and packaging teams to ensure you are aware of lead times for amendments to your packaging.
International
We are hopefully going to see the EU’s Circular Economy Act announced on 11 November, along with, again hopefully, a plethora of other smaller legislative updates.
I’ll be sitting down with Athene, our International Policy Representative to fully digest these announcements for the next edition in our Quarterly International Update podcast series (please see our recent episodes here!)
We value your input!
If you have anything you want me to cover or discuss next month, either here or in Beyondly’s regular podcast, please let me know at [email protected] and check out all our latest news and updates over on our website.
