This week for packaging suppliers

The implementing details of California's SB 54 extended producer responsibility (EPR) law for plastic packaging, including the final plan and fee schedule, are expected in October 2026; public comment on the draft closed on 14 August 2026. This is the next key milestone for packaging exported to the US.

What to do: Packaging suppliers and brands with US packaging business should track the fee announcement, as the fees will feed directly into cost calculations.

Source: CalRecycle SB 54 · reviewed 22 Sep

Under Article 7(8) of the Packaging and Packaging Waste Regulation (PPWR). The methodology will determine whether post-consumer recycled material (PCR) produced in China can count towards EU recycled content targets. Until the methodology is published, no commitment should be made that China-produced PCR will count towards EU targets.

What to do: Packaging suppliers and brands should track the implementing act and refrain from making commitments on this point until the methodology is published.

Source: PPWR Article 7(8)

What to do: New moulds and printing plates should include a replaceable marking area; otherwise complete sets may have to be scrapped in 2028.

Source: PPWR, Article 12

The mass balance approach is introduced on the same date. The 2026/27 rate is GBP 228.82 per tonne, charged where recycled content is below 30%. Packaging that relies on pre-consumer production offcuts to reach 30% will no longer qualify in the UK.

What to do: Packaging suppliers and brands should switch to post-consumer recycled (PCR) material sources and obtain supporting evidence about 12 months in advance.

Source: UK PPT · HMRC

The European Commission has made clear that Member States may not retain national labels; the material codes under Decision 97/129/EC may no longer be used thereafter.

What to do: Packaging suppliers and brands need to plan mould and printing plate changes well in advance.

Source: PPWR, Article 12

Under the Packaging and Packaging Waste Regulation (PPWR): recyclability grades A ≥95%, B ≥80% and C ≥70% (only grades A and B permitted from 2038). Minimum post-consumer recycled (PCR) content: 30% for contact-sensitive PET packaging and 10% for contact-sensitive plastic packaging made from materials other than PET (cosmetic bottles and jars fall into this category, which is less demanding than the 35% for other plastic packaging). Empty space ratio for grouped, transport and e-commerce packaging: ≤50%. Note that Annex V, item 5 (single-use cosmetic packaging in the hospitality sector) contains neither the word 'plastic' nor any ml or g threshold, so the ban applies to all materials; switching to glass, paper or aluminium does not avoid it.

What to do: Packaging suppliers and brands should move early towards mono-material and easy-to-separate designs. Dark carbon-black bottles, multi-material composites and pumps with non-separable metal springs are at high risk of falling below grade C. For the hospitality channel, options include wall-mounted refillable dispensers and large-format refill pouches, which also represent a new product opportunity.

Source: Reg (EU) 2025/40