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How Extended Producer Responsibility is on course to shake up UK recycling

By Imogen Shaw
28 April 2021

By Imogen Shaw

The introduction of the new Extended Producer Responsibility (EPR) due to come into force in 2023 marks the most significant reforms to the UK Packaging Waste Regulations since their introduction in 1997. It also represents a big shift in business’ future responsibilities for waste management.

It hasn’t enjoyed the media profile of several of the Government’s better known green initiatives, such as the Prime Minister’s Ten Point Plan, but EPR is on course to shift the full cost of collecting household waste from the taxpayer to producers. This means thousands of businesses are about to be subject to new reporting requirements – and potentially hit with significant additional costs.

The goal of EPR is to deliver something that looks a lot more like a ‘circular economy’ in UK packaging, where more packaging waste is recyclable and can be reprocessed into secondary products and resources. 

The idea is that producers of packaging placed on the market –  which usually means the relevant brand or packer/filler business – have an increased financial incentive to use packaging that is widely collected from household recycling. That should mean an increase in the amount of recycled content they use in their packaging and a reduction in unnecessary packaging material. 

The proposed EPR model will see producers pay the entire cost of managing their UK packaging at end of life. For recyclable products, this means from collection right through to transport and recycling. However, it also means producers will be picking up the tab for consumer education and the appropriate treatment of non-recyclable packaging waste. Currently, local authorities pay the majority of this cost, with UK packaging producers paying only a small percentage.

Liable businesses will face new fees that can vary “according to the design or composition of the products or materials to which the regulation relates, the methods by which they are produced or any other factor”, as set out in the Environment Bill currently before Parliament.

While it may not have a high profile, the enhanced EPR system is anticipated to be popular, with a recent survey finding 64% of people in the UK support the idea that producers and manufacturers should pick up the bill for recycling their products. 

The Government’s second consultation on EPR remains open until June 2021, but it has already committed to introducing the policy once the consultation has concluded. This consultation invites views and ideas on specific policy proposals for the introduction of EPR, including the scope of full net costs, the scheme’s governance and regulation, the nature of new producer obligations, and packaging waste recycling targets.

The two-year introduction timeline gives liable businesses a decent amount of time to plan for the expansion of the current producer responsibility system – and the increased fees that come with it. 

However, it’s highly unlikely that EPR will stop at packaging (UK electronics, batteries and vehicles are already covered by similar legislation). As well as the provisions for expanding the so-called ‘polluter pays principle’ into the new system for packaging, the Environment Bill makes provisions for new EPR regimes covering further product and waste streams to be introduced in future.

Industry advocates of EPR champion it as a solution that has a lot more going for it than simply incentivising recycling.  Visions for expanded EPR systems see them as an important tool for driving eco-friendly innovation in product design across the whole economy. So, UK businesses – especially those in retail or manufacturing – will need to take the hint and start thinking about what EPR could look like beyond 2023.