Overview of Extended Producer Responsibility and Consistent Collections
Extended Producer Responsibility
Please find below the answers to the following questions. These responses were written in July 2022. Please see the government response to the EPR consultation for more detailed information. What is Extended Producer Responsibility?
Where does EPR apply?
When does EPR Start?
What costs do EPR cover?
Who pays for EPR and what is the cost?
Do small companies still pay for EPR?
What is the difference between the EPR scheme and the PRN system?
How are local authorities paid for collections?
Are there targets for packaging recycling through EPR?
Does everyone pay the same amount?
How will quality be improved?
Is flexible and film recycling includes in the EPR consultation?
What do reprocessors and exporters need to do?
Who will run the EPR scheme?
Is biodegradable and compostable material counted as recyclable?
Does EPR cover business waste?
Does EPR cover the cost of litter?
What products are included in EPR?
Will EPR help with communication on what is recyclable?
What data do you need to collect?
What is Extended Producer Responsibility?
Extended producer responsibility (EPR) aims to make producers responsible for the cost of collection, managing and recycling of packaging and incentivise them to make their products recyclable by modulating fees based on the recyclability of products. It will also aim to reduce unnecessary packaging, increase quality and reduce litter.
EPR is across the whole of the UK.
When does EPR start?
Due to the deferral by a year of the ‘main’ packaging EPR regulations, the fees for packaging EPR will only be payable from 2025. From 2025 modulated fees will be in place based on the recyclability of packaging.
Packaging companies who handle and supply packaging will need to collect data from 1st January 2023. More information is available here.
EPR is intended to cover the full net (neccessary) cost of collection, managing, recycling and disposing of household packaging waste and on the go packaging disposed of in street bins. The scheme adminstrator will determine what is 'necessary'.
The existing PRN/PERN system will continue (with amendments) to provide evidence of recycling and will be market-based. This is for both household and non-household packaging.
Who pays for EPR and what is the cost?
Producers who place packaging on the market will pay for 100% of the EPR charge. Producers are:
- Brand Owner – those who package goods and sell them under their brand name. Were a brand not identifiable, then the obligation would fall to the organisation that carried out the packing or filling of the packaging.
- Importer – those who import filled-packaging
- Service Provider – those who hire out or lend reusable packaging
- Distributor – those who manufacture or import empty packaging and sell that packaging to anyone who is not an obligated producer
- Online Marketplaces – those who operate a marketplace whereby non-uk sellers can sell filled or empty packaging to UK consumers
- Sellers - those who sell filled packaging to the end-consumer
In the UK the scheme is estimated to cost £1.7 billion pa for all packaging types.
Do small companies still pay for EPR?
Companies are obligated if their turnover is £2m and they handle 50 tonnes of packaging.
If a company has a turnover of £1m and handle 25 tonnes they will need to report packaging placed on the market but not financially contribute.
What is the difference between the EPR scheme and the PRN system?
The PRN system was not designed to cover the full collection, sorting and recycling cost. It covers part of the cost of recycling and was designed to provide a mechanism to create more money in the system to encourage recycling when recycling targets are not being met then reduce costs when they are. This means there is no set price for PRNs and prices fluctuate significantly.
The cost of the PRN system is a shared obligation between raw material companies, convertors, packer fillers and sellers rather than having one point of compliance.
The PRN system will continue to be used alongside the new EPR scheme to show that recycling obligations have been met. There will modifications to the PRN system to address some of the issues with this system and the government has consulted on these. The PRN scheme will have a single point of compliance when EPR comes in.
How are local authorities paid for collections?
The scheme administrator will pay local authorities per tonne for the full net disposal costs of providing an efficient and effective system. The scheme administrator will monitor costs between comparable local authorities. They will also decide, and set out, how they calculate an efficient and effective service.
Are there targets for packaging recycling through EPR?
The packaging waste recycling target for 2024 will be 51% and 62% by 2030. This target takes into account the introduction of a collection scheme for films and flexibles by March 2027.
Priory to these targets the packaging waste business recycling target for 2023 will be the same as 2022 to allow businesses to prepare for the introduction of EPR in 2024.
Does everyone pay the same amount?
There is a modulation as part of EPR which is based on the recyclability of the material. This is based on what is technically recyclable and also what has the infrastructure in place to deal with it. This will be implemented from 2025 with recyclability assessments from October 2024.
In 2024 the fee producers pay will be calculated by apportioning the disposal costs for each material category.
There are a number of stages where quality of material should be improved.
- Modulated fees will help to drive a focus on design for recycling
- Consistent collection and improved labelling and communication will help to increase quality at the collection stage
- Material Facilities Regulations will be amended including more frequent sampling
- Local authorities will be compared to other comparable authorities to ensure an efficient and effective service is being provided
Is flexible and film recycling included in the EPR consultation?
Recyclable plastic film and flexible packaging is to be collected for recycling from households and businesses in the UK by 31 March 2027. This will be brought in through separate regulations across the devolved nations.
What do reprocessors and exporters need to do?
As the PRN/PERN system will remain reprocesssors and exporters will need to be accredited to this if they wish to issue PRN/PERNs. There will also be mandatory requirements to register with a regulator if you handle packaging and reporting requirements will include the quantity and quality of packaging waste handled.
Reprocessors and exporters will need to report on:
- Tonnes of packaging waste received on site (by material type and grade)
- Tonnes of non-recyclable or non-target packaging
- Tonnes of packaging waste to be reprocessed or exported following any further cleaning and sorting processes
- Tonnes of packaging material reprocessed on site and/or sent to an onward destination site or facility
Reprocessors and exporters will need to submit a sample and inspection plan to the regulator for approval.
Additional requirements will be needed for companies wanting to issue PRNs/PERNs.
- Exporters will need to give evidence of recycling by overseas reprocessors
- It is proposed that exporters will only be able to confirm a PERN once confirmation of receipt of material has been obtained by the final destination site
- An Annex VII form will also need to be submitted by exporters
- There will be a mandatory requirement for an inspection of an overseas sites by a third party operating in that regulation
Further requirements will also be looked at.
A scheme administrator will be appointed by Defra and will probably be within the public sector.
Is biodegradable and compostable material counted as recyclable?
Biodegradable and compostable material should be labelled as 'do not recycle' until the infrastructure and evidence based can be improved. This means it will attract a higher rate.
Does EPR cover business waste?
An interim solution will be put in place for managing packaging waste based on the current PRN/PERN system but with a single point of compliance. A taskforce will be established to review options for businesses for review in 2026/27.
Does EPR cover the cost of litter?
Producers will need to fund communications activities to prevent litter and cover the cost of managing packaging in street bins. Litter will not be included at this point although Scotland and Wales are looking to obligate producers for the cost of litter as well.
What products are included in EPR?
EPR covers packaging but does not include products which are included in the DRS (e.g. PET bottles).
Recyclable plastic film and flexible packaging is to be collected for recycling from households and businesses in the UK by 31 March 2027.
Will EPR help with communication on what is recyclable?
Packaging will have mandatory labelling with the Recycle Now recycle mark being used along with either 'recycle' or 'do not recycle'. This needs to take place by 31 March 2026. Plastic film and flexibles will not need to be labelled until 31 March 2027. There will be no de minimis. For unfilled packaging the manufacturer will need to provide recyclability information but the purchaser will need to factor in any alterations they make and their impact on recyclability.
There will also be funding from the EPR scheme for national communication campaigns as well as local campaigns.
What data do you need to collect for EPR?
Please click here.
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Extended Producer Responsibility Position Statement The UK plastics industry supports the government’s objective of reducing plastic waste and improving recycling rates. |
Useful links
Consistent Collections of Flexible Plastics (bpf.co.uk)
Position Statement: Deposit Return Schemes (bpf.co.uk)
Material Quality and Used Plastic (bpf.co.uk)
Understanding the Debate About Plastic (bpf.co.uk)
