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THEFOCUS
Frontier Sectors

Circular Economy & Recycling

For producers facing packaging fees and recyclers selling recovered material. We build the packaging, material and margin data that the new rules are billed on.

Our perspective

Packaging rules in the UK and the EU have turned a sustainability topic into an invoice. A producer's fee now depends on the weight, material and recyclability of every pack it places on the market, and those details usually sit in supplier specifications and spreadsheets rather than in the product record. Recyclers face the mirror problem: the margin on a tonne depends on contamination, yield and the price of the output bale, which are rarely measured on the same day. Over the next decade both sides will be paid, or charged, on data. We build the product, packaging and material records that make the bill and the margin calculable.

Market signals

  • 01

    The EU's circular material use rate was 12.2% in 2024, 4 percentage points higher than in 2004.

  • 02

    UK producers under packaging extended producer responsibility received their first invoices in October 2025, for April 2025 to March 2026, calculated on 2024 packaging data. Fees modulated by recyclability are introduced from 2026.

  • 03

    The EU Packaging and Packaging Waste Regulation has applied since 12 August 2026. The requirements that all packaging be recyclable and that plastic packaging contain recycled content apply from 2030.

What changes next

  1. Recyclability starts to change the bill

    UK packaging fees are modulated by recyclability ratings from 2026, so two packs of the same weight can carry different fees. Producers that hold recyclability data per component can redesign the costly formats first.

  2. Product passports reach batteries

    The EU battery passport becomes mandatory for electric vehicle, light transport, industrial and larger storage batteries from 18 February 2027. It is the first product group under the EU's digital product passport, and the data model it uses will be extended to other categories.

  3. Each EU market registers separately

    Under the new EU packaging rules, a business selling into several member states must register and report packaging data in each country of sale. Cross-border sellers, including UK exporters, will need one packaging dataset that can serve every national scheme.

Business challenges

  1. 01

    Packaging data outside the product record

    Weights and materials sit in supplier specifications, emails and one-off surveys. Each EPR return becomes a project, and errors go straight into the invoice.

  2. 02

    Fees nobody has allocated

    The packaging fee arrives as one invoice. Until it is allocated to products and channels, range and pricing decisions ignore a cost that differs sharply between pack formats.

  3. 03

    Recycled content claims without evidence

    Suppliers state recycled content in different ways and with different certificates. Without a register, a claim made in marketing or a regulatory return cannot be traced to its evidence.

  4. 04

    Recycler margins seen at month end

    Contamination and yield are recorded on the weighbridge and the line, while output prices sit with sales. A load that lost money is identified weeks after the supplier has delivered the next one.

Where the opportunity sits

Packaging cost visible per product

Adding the expected fee to each product's margin shows which pack changes pay for themselves and which products carry the most regulatory cost.

One dataset for every scheme

A single packaging record that serves UK EPR, EU national schemes and customer questionnaires removes the separate return each one usually needs.

Recovered material sold on measured quality

Recyclers that record yield and contamination by supplier can price incoming material on what it returns and sell output with the quality evidence buyers ask for.

How we approach it

We start read-only with the product catalog, supplier specifications, previous packaging returns and invoices, or, for recyclers, with weighbridge records, production logs and sales data. We trace one product range from supplier specification to the reported tonnage, or one material stream from gate to sale, and note where figures are estimated or retyped. Findings become a prioritized task list, each item with an owner and an acceptance check. If the client wants us to build, the same team delivers the packaging records, fee reporting, sourcing requirements and storefronts, documented and left in the client's own accounts. We work with retail, e-commerce and consumer products businesses, where most packaging obligations land. Recyclability testing and certification, environmental permits, waste carrier and compliance scheme registration, legal interpretation of the regulations and sign-off of environmental claims stay with accredited bodies, compliance schemes and the client's own advisers.

How our experience is evidenced

Circular economy and recycling form a frontier sector where THEFOCUS applies its capabilities in product data, regulatory reporting, sourcing and commerce. No anonymised engagement in this sector is published, and no results are claimed.

How an engagement with THEFOCUS starts

A first conversation is about your situation. If there is a fit, we propose a scoped diagnostic with a fixed deliverable before any larger commitment.

Discuss this with us
  1. 01

    A working conversation

    Forty-five minutes with the person who would lead the work. We ask about the decision, the systems behind it and the deadline.

  2. 02

    A scoped diagnostic

    Read-only access, a fixed timeframe and a written finding: what the records show, what it costs and what to change first.

  3. 03

    A plan you can act on

    Changes, owners, measures and exclusions in writing. The same team then builds and measures, or hands over cleanly.

One accountable team
The people who diagnose also build the systems and measure the result.
Partners chosen per problem
Independent specializts join for the parts that need them, under one contract.
Records before dashboards
Orders, ledgers and logs are reconciled before any recommendation depends on them.

info@thefocus.solutions

Questions executives ask

Can you file our packaging EPR return?

We build the packaging data and calculations your return draws on, with each figure traceable to a supplier specification or measurement. Submission and the declaration remain yours or your compliance scheme's.

Do you assess whether our packaging is recyclable?

No. Recyclability ratings come from the published assessment methodology and, where needed, from testing by accredited bodies. We record the ratings and the evidence against each component and show what they cost.

We sell into several EU countries. Where should we start?

With one packaging dataset per product and component, held in the product record. Each national registration then draws on the same figures instead of a fresh survey for every country.

Discuss this with us

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