Wrap has acted to try to clear up major confusion over the nation’s growing mountain of soft plastic, after it emerged many films and other types of flexible packaging have been incorrectly reported by suppliers under the EPR tax system.
Figures from Wrap suggest more than a quarter of all plastic packaging placed on the UK market is in the form of bags, wrappers and films, amounting to a massive 450 kilotonnes a year. Concern has been growing that new rules to try to push companies away from using the materials have been widely misinterpreted.
It has been revealed that producers have often been incorrectly assuming that their soft plastics material qualified to be rated as ‘amber’ under PackUK’s Recyclability Assessment Methodology (RAM) take-back protocol, which came into force for the second year of EPR.
However, the clarification stresses that unless strict conditions are met, such materials should be classified as red, meaning ‘no or low’ recyclability rather than the amber rating meaning ‘moderate’.
Under the RAM traffic light system, producers face much higher bills for red-rated products.
The clarification stresses that producers must hold full, auditable evidence that every take-back requirement is met, including:
- Accessibility within five miles for 75% of the UK population
- No conflict with kerbside collections
- No brand restrictions
- No purchase requirement
- Evidence of actual recycling and traceability throughout the process
In the absence of complete evidence, suppliers have been told the correct rating is red.
Under the government’s landmark simpler recycling reforms, from 31 March 2027 all local authorities in England will be required to implement weekly or fortnightly kerbside collection of soft/flexible plastics, which includes items such as bags, wrappers and films.
Currently levels of collection have been reported as below 10%, with concern also raised at the lack of structure in the UK to process soft plastic for recycling into the circular economy.
A report by Ecosurety in September revealed major fears over the lack of kerbside services and the lack of capacity in recycling facilities, with the FlexCollect trial confirming the UK is currently well short of the capacity needed to meet the demands from 2027.
Robbie Staniforth, innovation and policy director at Ecosurety, said: “There has been some confusion amongst industry as to whether flexible plastic packaging can be reported as ‘amber’ under the RAM.
“Until mandated collection under the ‘simpler recycling’ reforms in 2027, flexible plastic packaging will be assigned a ‘red’ RAM outcome at the ‘collection’ stage due to a low number of local authority collection services of this material from the kerbside in the UK.
“This is unless the obligated packaging producer has evidence that flexible plastic is part of a valid take-back scheme and has evidence of recycling, in which case it will achieve an ‘amber’ rating at the ‘collection’ stage.”
Jude Allan, OPRL MD, said: “The recent confusion around flexible plastics shows that recyclability assessments are complicated and nuanced.
“When we hear that clarification is needed, it is an important part of OPRL’s role to provide certainty for our members.”
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