As Scottish packaging businesses look towards 2026, Roger Wright, waste strategy & packaging manager at Biffa, says that the policy landscape remains one of movement, pause, and partial delivery
There’s huge ambition in circular economy rhetoric, but the reality for packaging producers, converters, and brand owners is uneven. Some reforms are finally landing and steadily influencing decisions – others delayed, diluted, or unresolved. Understanding what is (and isn’t) changing is essential for planning investment, material choices, and packaging design.
What IS happening
The most consequential regulatory development for 2026 is the evolving Extended Producer Responsibility for packaging (pEPR). As the scheme is embedded, modulated fees will soon bite more clearly, sending stronger price signals around material choice, recyclability, and design. For the first time, packaging that’s harder to recycle or more expensive to manage at end-of-life faces materially higher costs. If implemented and enforced effectively, we could see a genuine shift away from treating EPR as a compliance exercise towards leveraging it for better packaging design.
Alongside pEPR, previous reforms to the Packaging Waste Recovery Note system and the Plastic Packaging Tax are steadily driving improvement. Namely, the introduced mandatory certification for mechanically recycled plastic under PPT is an important step in tackling fraud, improving data integrity, and restoring confidence in recycled content claims.
Momentum builds around innovation and collaboration. Digital watermarks and 2D barcodes are moving from pilot to early adoption, offering scope to improve sorting accuracy and reduce contamination. Moreover, closed-loop partnerships between brands and recyclers are increasingly common.
Material optimisation is progressively central to decision-making. Plastics remain essential for many applications, particularly where food safety, lightweighting, and carbon performance are critical.
Attention is firmly on design for recyclability and mechanically recycled content, with continued calls to raise the PPT threshold to 50% to unlock further investment.
Aluminium still performs strongly given high recycling rates and relatively lower pEPR costs.
Glass remains important in premium and food-safe uses, albeit under pressure amid energy intensity and transport emissions.
What’s not happening
Simultaneously, several high-profile Scottish policy proposals remain stalled. We won’t see the proposed ‘Latte Levy’ on single-use drinks cups in 2026. Hopes of a 25p charge on paper coffee cups are paused again, with the Scottish Government pushing to develop a fair, effective system. This prolongs business uncertainty rather than providing clarity or incentive to invest in reuse infrastructure.
Similarly delayed is the ban on landfilling biodegradable municipal waste. Once intended to include paper and cardboard, enforcement requires a (lacking) sufficient waste treatment capacity. This exposes an ongoing gap between policy ambition and infrastructure readiness, while limiting how far packaging design signals are reinforced by downstream consequences.
More broadly, expectations around ‘paperisation’ are increasingly realistic. Replacing plastic with fibre-based materials isn’t always more sustainable, particularly where products are plastic-lined, heavily contaminated, or poorly recycled. Prevalently, policy hasn’t caught up with these nuances, running the risk of unintended outcomes rather than genuine emissions reductions.
What this means for businesses
Next year’s picture is mixed. There’s headway where regulation finally meets market behaviour, particularly through pEPR, recycled content standards, and emerging innovation. However, delays to flagship Scottish measures and infrastructure constraints mean some of the strongest circular economy signals remain muted.
Packaging businesses must navigate this uneven landscape. Inflationary pressures and supply chain volatility continually squeeze margins, so it’s harder to justify investment without clear regulatory certainty. As consumer and regulatory expectations intensify, standing still is no longer an option.
2026 should be a moment to consolidate progress, prioritise material optimisation and end-of-life performance, and prepare for the bolder reforms ahead. The opportunity exists to build packaging systems that are more circular, resilient, and credible, but only if policy intent is matched by delivery.
