NEW analysis published by compliance scheme Beyondly has found producers of fibre-based composite (FBC) packaging like liquid cartons, sandwich wrappers and ready meal containers may have been ‘significantly overcharged’ by the packaging Extended Producer Responsibility (pEPR) scheme.
The report found that the £461 per tonne pEPR fee charged for FBCs has been incorrectly calculated, with the true figure being £34/t lower on a conservative analysis of available data sources, and potentially as high as £92/t. Applied to the fees paid by brands for FBC materials last year, this suggests that fees could have been overpaid by between £6.3 million and £13.7 million.
A team of researchers at Beyondly authored the review, led by packaging experts Charlotte Davies, Dr Liz Wood and Alex Hilton. The analysis was commissioned by ACE UK – The Alliance for Beverage Cartons and the Environment and has now been submitted to PackUK with a call to urgently review future fees.
This report identifies several areas where current assumptions ‘materially overstate’ the cost burden applied to FBC packaging. The most significant issue relates to the cost to local authorities of collecting packaging for recycling or disposal, with the scheme currently charging £509/t to collect FBC compared with just £264/t for paper and card despite the two having similar properties.
The collection figure is calculated based on the volume of packaging rather than its weight and may overstate the amount of space taken up by FBCs in two ways.
The model appears to assume that more of the FBC category is made of liquid cartons than is actually the case, which has an impact as cartons take up more space in collection vehicles. It also assumes that non-liquid FBCs have the same bulk density as the card category, which is predominantly made up of bulky corrugated cardboard boxes.
By using available data on both the liquid/non-liquid split, and the estimated bulk density of non-liquid FBCs, Beyondly found the collection costs applied may have been ‘significantly overstated’. Amending the model would bring the collection costs for FBCs closer to those of paper and card, and deliver a significant reduction in the fee per tonne of between £34/t and £92/t.
Charlotte Davies, senior consultant – resource efficiency & circularity, Beyondly said, “The current fee of £461/tonne appears to be disproportionately high for fibre-based composites. The review identifies two key drivers of overcharge. The bulk density assumed for non-liquid cartons is based on corrugated cardboard rather than the lighter retail packaging formats that dominate kerbside FBC waste.
“The market split between liquid and non-liquid cartons also overstates the share of low-density liquid cartons. Since recyclate collection costs represent nearly two-thirds of FBC waste-management costs and are apportioned by volume, both factors inflate the volume allocated to FBC waste and therefore the proportion of collection cost it bears.
“Combined, data revisions could reduce the disposal fee by approximately 8%. The review also highlights widespread misreporting of FBCs as paper and card and demonstrates the influence this had on disposal fee cost for 2025.”
The review also highlights a number of other issues, which may further over-inflate the FBC fee and recommends further research and analysis of data.
It sets out that collection costs currently assume that packages like liquid cartons are never compacted during the process either by consumers or collection vehicles. This would overstate the volume these materials occupy in the waste stream, as cartons take up more space when they have not been flattened.
The report also explores concerns around the misreporting of FBCs as paper and card, with many packages in the two categories being similar in appearance and performance.
Ben Powell, head of external affairs, ACE UK, added, “This report shines a light on the true extent of the artificially high pEPR disposal fees charged to producers of FBC packaging, including liquid cartons. It is clearly implausible to charge nearly twice as much for local authorities to collect a tonne of FBC than a tonne of paper and card. The impact of this discrepancy alone seems to have cost brands millions of pounds more than it should have done last year.
“As the pEPR system beds in, we know that the data and assumptions used will continue to improve, leading to a more accurate cost being applied to every package on the market. We were really pleased to work with Beyondly on this excellent report, which offers robust recommendations backed up by evidence. We look forward to continuing to work constructively with PackUK to ensure disposal fees are fair for all packaging types, which is essential if we want to make our shared sustainability goals a reality.”
