Beyondly urges clearer roles for UK pEPR and Packaging Recovery Note systems

The UK’s packaging EPR (pEPR) should be complementary to the country’s longstanding Packaging Recovery Note system, according to Beyondly. The regulatory compliance service says the pEPR and PackUK (the pEPR scheme administrator) are tasked with funding and improving household packaging collection. 

Meanwhile, the Packaging Recovery Note system uses recycling data to help producers meet their legal packaging obligations, underpinning recycling targets, and driving investment in recycling capacity. 

Alex Hilton, director of Policy and Public Affairs at Beyondly, tells Packaging Insights that “clear and distinct roles will help avoid duplication and ensure both parts of the system work effectively together.”

“If pEPR provides the front-end funding and service improvements, and the Packaging Recovery Note system continues to drive recycling performance and investment, the UK can build a more transparent, efficient, and future-proof packaging system that delivers better outcomes for businesses, consumers, and the environment.”

Hilton says the evolution of the Packaging Recovery Note system should be considered alongside broader pEPR developments, including PackUK’s recently updated Recyclability Assessment Methodology (RAM) 2027, which further links producer obligations to real-world recyclability.

The key changes are not about administration or reporting, but about the UK’s definition of recyclability becoming “increasingly tied to real-world recycling outcomes rather than theoretical recyclability,” he adds. 

Why RAM matters

Hilton, who helped develop the original RAM methodology while working at PackUK, says the latest RAM 2027 update illustrates how the pEPR can better reflect the realities of packaging collection, sorting, and reprocessing within UK infrastructure.

Alex Hilton, director of Policy and Public Affairs at Beyondly.As producers face stronger design incentives under the revised methodology, he argues the UK’s longstanding Packaging Recovery Note system must also evolve to provide the transparency, investment, and market confidence needed to support those recycling outcomes.

Hilton says a positive of RAM 2027 is the inclusion of PFAS restrictions in the “recyclability conversation.”

“Packaging containing PFAS above the defined thresholds will receive a red rating. This is significant because it moves RAM beyond pure recyclability and into the wider question of material safety and chemical circularity.”

He continues that food-contact fiber packaging is similarly now facing greater scrutiny. “Certain paper and card formats designed for heating food will automatically receive a red rating, reflecting concerns around contamination and practical recyclability.”

At the Packaging Innovations trade show in Birmingham this February, the UK Foodservice Packaging Association expressed concern regarding the “confusion” the pEPR is causing within the industry. At the same time, Ecosurety, the country’s pEPR compliance scheme, and packaging companies Coveris and Xampla argued that regulatory pressure has sparked innovation in design for recyclability.

RAM 2027 also places more emphasis on components rather than just primary materials, continues Hilton. “Trigger sprays, labels, and other attached elements are increasingly recognized as factors that can determine whether a package is recyclable in practice.”

“In other words, the question is no longer ‘Can this technically be recycled somewhere?’ but ‘Does the UK currently collect, sort, and recycle it at scale?’”

Room for reform

To complement RAM’s stronger focus on real-world packaging recyclability by design, Hilton argues that the current Packaging Recovery Note system should evolve to improve transparency, accountability, and long-term investment across the recycling value chain.

Hilton says that the RAM 2027 update illustrates how the pEPR can better reflect the realities of packaging collection.“Looking ahead, there is an opportunity to improve transparency through better reporting, data sharing, and visibility of system performance. Accountability can be strengthened by clearly demonstrating how producer funding and recycling evidence contribute to environmental outcomes,” he says.

“The playing field between Packaging Recovery Note and Packaging Export Recovery Notes should be leveled to support domestic recycling and reduce fraud where the chain of custody ends overseas.”

A recent report by the UK-based recycling and waste management company Viridor warned that the UK’s plastics recycling capacity is diminishing despite regulatory efforts to expand collection. Viridor told Packaging Insights that there is a risk the UK may collect more plastic than it can process domestically. 

Hilton further sees an opportunity to reform the Packaging Recovery Note to encourage longer-term investment by providing greater certainty and confidence for recyclers and investors.

“It should use more comprehensive performance measures, including carbon reduction, resource efficiency, and broader circular economy outcomes alongside recycling rates, and create stronger mechanisms for collaboration between producers, recyclers, compliance schemes, local authorities, and government.”

Building a reliable market

Packaging Recovery Note reform should build on the strengths of the existing framework rather than replace them, says Hilton. It should be changed in a way that preserves the efficiency and recycling performance it has already delivered, he adds.

“The Packaging Recovery Note system has been one of the key drivers behind the UK’s growth in packaging recycling over the past three decades. It has delivered significant increases in recycling rates, from 27% in 1997 to 70% in 2025, while maintaining a relatively cost-effective approach for obligated businesses.”

The system’s market-based structure has encouraged competition and significant investment in recycling infrastructure, while providing clear evidence and a market mechanism for demonstrating compliance, says Hilton. 

“However, no system should stand still, especially when opportunities to improve it are clearly visible. Businesses, recyclers, and policymakers all benefit from clearer data, better visibility of how funding supports recycling outcomes, and greater certainty to encourage long-term investment.”

The Packaging Recovery Note system should evolve to complement RAM's focus on real-world recyclability, Hilton argues.In 2022, Robbie Staniforth, Ecosurety’s innovation and policy director, told Packaging Insights that the Packaging Recovery Note system needs urgent improvement to resolve issues including price fluctuations, instability, underreporting, and “inferior” materials.

Following a government consultation at the time, proposals were made to extend the compliance trading period with the aim of reducing or removing price fluctuations and “cliff-edge” price negotiations. 

Hilton explains that the primary role of the Packaging Recovery Note was to ensure the UK meets packaging recycling targets by creating a market mechanism that rewards the collection and recycling of packaging materials. 

“By that measure, it has been very successful and has played a fundamental role in delivering substantial growth in recycling rates,” he says.

“That said, we all have a right to expect more from modern resource management systems. Today’s debate is not whether recycling targets are being achieved, but how we can maximize the environmental value delivered through the system.”

For Hilton, that means looking beyond tons of recycled packaging alone and considering factors such as material quality, carbon impacts, infrastructure investment, and industry confidence. Rather than viewing this as a criticism of the Packaging Recovery Note system, it should be seen as the natural next stage of its evolution.

“The answer is not to discard a system that has delivered results, but to strengthen it through better data, greater transparency and closer alignment with the UK’s circular economy objectives,” Hilton concludes.