Packaging radar

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