The Foodservice Packaging Association has asked PackUK to clarify how a proposed 25 parts-per-billion PFAS threshold in the 2027 Recyclability Assessment Methodology will be evidenced and applied. The draft rule would give any food packaging exceeding the threshold for an individual or total PFAS an automatic red rating, tighter than the EU's PPWR limits. The association questions whether chemical-content criteria should override recyclability outcomes for packaging that can otherwise be collected, sorted and reprocessed, and says it will keep working with PackUK on the issue.
Why this mattersA stricter UK PFAS threshold than the EU's could force separate compliance and testing regimes for foodservice packaging producers selling into both markets.
- RAM 2027 sets a 25 parts-per-billion threshold for any individual or total PFAS, triggering an automatic red rating.
- EU PPWR sets 25 ppb for an individual targeted PFAS and 250 ppb for the sum of targeted PFAS, plus a separate 50 ppm limit including polymeric PFAS.
- The FPA is seeking clarity on what evidence (supplier declarations, technical specifications, test reports) will be accepted to demonstrate compliance.
- The association questions whether chemical and food-contact compliance criteria should determine a recyclability rating.
- The FPA says it will continue working with PackUK on the issue.
New UK Environment Agency data shows 61.8% of flexible plastic packaging assessed under the Recyclability Assessment Methodology (RAM) received the lowest 2025 rating, according to analysis by circular economy specialist Reconomy. Under packaging EPR (pEPR) fee modulation, due to begin in the scheme's second year, red-rated packaging will cost 20% more per tonne than amber-rated packaging, with Defra's RAM 2027 guidance applying to packaging supplied from 1 January 2027. Large producers with a high share of red-rated flexible plastics could face materially higher PackUK invoices.
Why this mattersFee modulation shifts cost toward flexible-film packaging unless producers secure take-back scheme evidence, pushing redesign and reformulation across UK food packaging.
- 61.8% of flexible plastic packaging assessed under RAM received the lowest (red) rating in 2025, per Environment Agency data analysed by Reconomy.
- Red-rated packaging will cost 20% more per tonne than amber-rated packaging under pEPR fee modulation.
- RAM v1.1 applies to packaging supplied in 2026; RAM 2027 guidance applies to packaging supplied from 1 January to 31 December 2027.
- Total UK packaging tonnage reported by large producers fell 1.2% (about 135,000 tonnes) to 10.97 million tonnes in 2025, from 11.11 million tonnes in 2024.
- Plastic packaging tonnage fell by approximately 52,300 tonnes and glass by around 51,600 tonnes in 2025; aluminium rose by about 8,700 tonnes.
- The first pEPR assessment year began 1 April 2025, with the first invoices issued in October 2025.
- Steel packaging tonnage fell by 25,500 tonnes and fibre composite by 12,200 tonnes in 2025
