The Environment Agency has changed the rules for fibre-based composites (FBCs). This small detail could mean a big win for paper cups in curbside collection—if the government acts in time.
FBC packaging with less than 5% non‑fibre material1 is now classified as paper and board. Many paper cups already meet this standard but still cannot go into household kerbside recycling2 under Simpler Recycling rules.
As someone who works closely with paper packaging, I see the gap between what the new definition allows and what recycling rules still forbid. The FPA says this “stateless” status needs to end.
What has changed in the FBC definition?
The change moves the new definition ahead by over a year.
As of now, FBCs with less than 5% non‑fibre mass count as paper and board under EPR rules, instead of waiting until 1 January 2026.
This matters because EPR (Extended Producer Responsibility3) fees for this paper and board category could be up to 80% lower than for FBCs with more non‑fibre content. The definition now matches the Recycling Assessment Methodology4, bringing long‑needed consistency.
| Classification | Non‑fibre content | EPR Fee Impact |
|---|---|---|
| Paper & board (P&B) | ≤ 5% | Lowest fee level |
| Fibre-based composite (FBC) | > 5% | Significantly higher fee |
Martin Kersh of the FPA says that this not only reduces fees but also makes assessing and reporting packaging more straightforward.
Why are paper cups still excluded from kerbside recycling?
This is the question raising frustration in the industry.
Many modern paper cups now have coatings under the 5% non‑fibre limit—yet they cannot go into household recycling kerbside bins.
The logic gap:
- A fibre‑based food box with 4% PE coating is allowed at kerbside.
- A paper cup with the same 4% PE still cannot go into kerbside recycling2.
Previously, a ban on kerbside collection for cups was paired with a planned mandatory retailer collection system5. But Minister Mary Creagh cancelled that, leaving no main recycling route for many paper cups.
What is the FPA calling for?
The FPA is urging two possible changes—preferably both.
They want paper cups that meet the ≤5% non‑fibre rule to be collected at kerbside, and also to set a timetable for mandatory retailer take‑back.
The reasoning:
- If other containers with the same material ratios can be collected in household bins, cups should not be excluded.
- Retailer take‑back would give an extra secure collection stream, catching cups that kerbside systems miss.
Right now, cups are in “stateless” limbo—a packaging type recycled in some back‑end systems but banned from front‑end collection from homes.
| FPA Request | Benefit |
|---|---|
| Allow kerbside collection | Increase recycling volume and fairness |
| Set take‑back timetable | Dedicated route for foodservice cups |
As someone in packaging, I see this as a real opportunity to make recycling simpler and more effective for everyone.
Conclusion
With the FBC definition change, many paper cups now qualify as paper and board. The FPA says it’s time to end the kerbside ban and reinstall retailer take‑back—before this packaging type stays stuck in recycling “statelessn
Understanding FBC packaging is crucial for grasping recycling regulations and their implications for sustainability. ↩
Exploring kerbside recycling can provide insights into effective waste management and recycling practices. ↩
Learning about EPR can help you understand how producers are held accountable for their packaging waste. ↩
This methodology is key to understanding how recycling systems evaluate materials for processing. ↩
Discovering this system can shed light on how retailers can contribute to effective recycling solutions. ↩