Regulatory Decision 118: pEPR – definition of fibre-based composite material (FBC)
This Regulatory Decision (RD) is valid until 31 January 2027 by which time it will be reviewed. You should check back at that time to ensure the RD is still valid.
Natural Resources Wales (NRW) can withdraw or amend this RD before the review date if we consider it necessary. This includes where the activities that this RD relates to have not changed.
Regulatory Decision
This RD allows producers to adopt the forthcoming revised meanings of “fibre-based composite material” and “paper or board” and to apply them to their collection and reporting obligations for 2025 before the upcoming amendments to these definitions in the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (‘the 2024 Regulations’) come into force.
This Regulatory Decision (RD) does not change your legal requirement to collect and report fibre-based composite material and paper or board packaging data in accordance with the 2024 Regulations, for the 2025 reporting periods. This being 1 January to 30 June 2025 and 1 July to 31 December 2025 for large producers and 1 January to 31 December 2025 for small producers.
NRW will not take enforcement action against you if collect and report fibre-based composite material and paper or board packaging data for the 2025 reporting periods, based on the meanings of fibre-based composite material and paper or board contained in the upcoming amendments to the 2024 regulations, as follows:
Fibre-based composite material means packaging material which —
(i) is made of paperboard or paper fibres, with one or more layers of plastic, and which may also have layers of other materials, to form a single unit that cannot be separated by hand; and
(ii) is not in the paper or board packaging category.
Paper or board includes packaging material which is within the description in sub-paragraph (i) of the definition of fibre-based composite material, if the producer who supplies the packaging can provide evidence that its layer or layers of plastic are not more than 5% of the packaging material by mass.”
Conditions you must comply with
This RD does not apply to any other data collection or reporting obligations under the 2024 Regulations and you must ensure you fully comply with all other requirements.
Enforcement
This RD does not change or remove any of your legal obligations under the 2024 Regulations.
However, NRW will not normally take enforcement action if you do not comply with the specific legal requirements set out in this RD.
Contact
If you have any questions about this RD please e-mail packaging@naturalresourceswales.gov.uk.