Fibre-Based Composite Packaging Classification Update
The Environment Agency (EA) has confirmed that packaging producers may begin using the updated definition of fibre-based composite (FBC) packaging ahead of its formal adoption. This change forms part of wider adjustments to the Recycling Assessment Methodology (RAM) under the extended producer responsibility (pEPR) scheme for packaging.
Enforcement Paused for Early Adoption
In a Regulatory Position Statement (RPS 351) published on 7 July 2025, the EA stated it will “not normally take enforcement action” against those who choose to adopt the updated classification early. In essence, the regulator is offering producers the opportunity to switch now without fear of penalties – even though the revised definition won’t legally apply until 1 January 2026.
What’s Changing?
Under the new criteria, packaging will be considered paper or cardboard if plastic accounts for no more than 5% of the total material weight. Where the plastic content exceeds that threshold, the item will remain categorised as fibre-based composite packaging.
This update is a departure from the current standard, which defines FBC packaging as a combination of paper fibres and plastic layers that form a single, inseparable unit – like takeaway coffee cups with plastic linings.
Why It Matters
Aligning with RAM’s revised classification means simpler reporting and consistency across environmental regulations. Importantly, the recyclability of a package now directly influences the disposal costs producers will face – a concept referred to as “fee modulation”.
Better classification should lead to more accurate assessments under RAM, ensuring that producers are fairly charged based on how recyclable their packaging actually is.
Looking Ahead
From January 2026, all producers will be expected to comply with the new definition. But for those ready to transition now, the EA’s statement offers both clarity and flexibility. By making changes ahead of the deadline, producers can prepare for the financial and compliance impacts of RAM while contributing to a more efficient and transparent recycling system.