Fibre-based composite and paper/board reporting update

A Regulatory Position Statement (RPS) was released on 7 July by the Environment Agency concerning the reporting of fibre-based composite (FBC) and paper/board reporting under the packaging EPR data submissions.

The EPR regulations currently define FBC as paperboard or paper fibres, with a layer of plastic, which may also have layers of other materials, to form a single unit that cannot be separated by hand.

However, amendments to the EPR statutory instrument, which will be applicable for data reporting from 2026, modify the definition. It confirms that FBC packaging where “its layer or layers of plastic are not more than 5% of the packaging material by mass” should instead be reporting under the paper/board category.

Once this amendment is in place, the definition of FBC and paper/board will align with those of the RAM, making it easier for producers to both report and assess their packaging. Until then, if producers choose to report FBC in line with the forthcoming definition, the agency “will not normally take enforcement action”, even though the RPS does “not change [a producer’s] legal requirement to comply” with the current EPR reporting regulations and definitions.

We recommend producers take advantage of the RPS now and report both their FBC and paper/board formats in line with the forthcoming amended definitions, to ensure a cohesive approach to RAM reporting this year and accurate charging of fees and modulation factors.

You can read the full RPS on fibre-based composite and paper/board reporting here.

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If you have any questions about your packaging EPR or RAM data submission, please contact your account manager or help desk for assistance.