← AFME Industry Intelligence
AFME Analysis

Packaging recyclability rules create a defined cost penalty for flexible films

New recyclability classifications will make red-rated flexible packaging more expensive under Packaging EPR, increasing pressure for material substitutions that must be validated on food-production lines.
18 September 2026 · Regulatory & Standards

What happened

Analysis of Environment Agency packaging data indicates that 61.8% of flexible plastic packaging assessed during 2025 received the lowest, red recyclability rating. Under Packaging Extended Producer Responsibility fee modulation, red-rated packaging will cost 20% more per tonne than amber-rated material. RAM 2027 introduces clearer material-specific rules, automatic red classifications and stronger evidence requirements. Flexible food-contact packaging will generally remain red unless qualifying take-back evidence supports an amber rating.

Why it matters to food manufacturing engineers

Commercial pressure to replace laminates and flexible films will increase. Material substitutions can alter sealing temperatures, dwell times, jaw contamination, cutting, registration, shelf life, gas barriers, line speed and leak rates. A lower EPR charge can be outweighed by higher production losses or waste if a replacement material is introduced without engineering and technical validation.

Operational impact

Factories with high volumes of flexible packaging could face increased compliance cost and accelerated packaging-change programmes. Engineering, Technical, Packaging and Procurement teams will need to coordinate trials, equipment settings, quality limits and approval evidence before new structures enter production.

AFME perspective — what to watch

AFME interpretation: packaging compliance must be treated as a production-system issue rather than a material-purchasing decision. Engineering action: build a packaging-risk matrix showing annual tonnage, anticipated RAM rating, EPR exposure and line compatibility, then require controlled trials covering sustainable speed, seal integrity, shelf life, coding, detection systems and changeover loss.