Extended Producer Responsibility
Extended Producer Responsibility (EPR) for packaging (for all materials) aims at ensuring producers pay the full cost of dealing with the waste they produce. This cost transfer, from the public purse and those who dispose of packaging waste, is intended to incentivise producers to question whether the packaging they use is necessary or could be reduced or perhaps even omitted. It is also intended to encourage the take up of reuse or refill models, to help meet waste reduction targets. It could also arguably reduce litter too.
What is it intended to cover?
EPR is intended to cover full net costs regarding the end of the product’s life and associated litter costs, as well as communication programmes, promotion and education campaigns. In the UK, the PRN system presently recovers only a portion of the costs necessary to ensure recycling targets are met. This situation will remain until a review is carried out in the future.
EPR covers household and household-like waste, not commercial and industrial (C&I) business waste.
What about the timing?
Data collection started in January 2023, with reporting commencing from October the same year. The data that has been reported will be used to calculate the fees that will be paid for 2024. For plastics, this is initially for rigid forms only but will be extended to flexibles in 2025. The concept of eco modulation, based on recyclability, will be introduced in 2025, with the possibility of including environmental impact assessments at a later date.
How is it operated?
The scheme will be run by a System Administrator, which will be a public (government) body. A person was appointed to oversee this in January 2024. They will be responsible for the day to day running of the system, collecting the fees, defining eco-modulation (when it is introduced), paying local authorities, marketing and education.
Who pays and what is the expected cost?
Producers of packaging placed on the market are expected to pay. This will include brand owners, packer/fillers and packaging manufacturers that supply to companies that fall below the de minimis (turnover of £1million p.a. and 25 tonnes of packaging handled).
In the UK, the anticipated cost of the proposed scheme is estimated at between £1.7billion per year for all packaging types, being divided between materials on a percentage basis by weight.
Are there any complications?
It is important that when defining the recyclability of materials that all recyclable plastics are recognised and collected. This is the approach that has been adopted in many other European members states with an operational EPR system.
When allocating costs and modulating fees, it is imperative that both resource use and resource efficiency are considered, alongside end of life considerations, to establish the relative carbon impacts.
In conclusion…
The UK plastics industry supports the government’s objective of reducing plastic waste and improving recycling rates. Refining existing EPR obligations is a means of improving the design of plastic packaging to aid recycling and paving the way to harmonising the various kerbside collection schemes across the UK. However, there are several complexities to take into consideration.
Modulated fees should not solely be based upon whether an item is recyclable or not. It should ensure that resource efficiency is incorporated as well as the recyclability of the product.
As producers are to bear the costs of collection, then a producer advisory board should determine how the funds collected are allocated. Funds should be used to support achieving consistent collection of all plastics within the UK and developing an improved recycling infrastructure, including sorting. Also, any oversight and the monitoring of compliance needs to be detailed in the upcoming legislation.
Local councils should have an obligation to collect waste for recycling in the most efficient way, ensuring high consumer participation and delivering materials for sorting and recycling with the lowest level of contamination. Local councils should be rewarded and incentivised based on achieving best practice, for example on consumer engagement, with recycling initiatives and the efficient collection of segregated waste for recycling.
The System Administrator should be a private body, not a public one. The most successful systems elsewhere in the world (Fost Plus in Belgium is a good example), are privately run.
Originally published June 2019
Last reviewed and updated July 2024
