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Do you know what your Extended Producer Responsibility obligations will be?

17th May 2021

After much anticipation, the UK government has released its second consultation on a new Extended Producer Responsibility (EPR) system for packaging waste.

This latest consultation represents a crucial opportunity for brand owners, manufacturers and stakeholders to shape a major overhaul in waste packaging legislation. Respondents have until June 4, 2021 to provide feedback to the government.

What is the purpose of the new EPR system?

The overall purpose of the proposed new system is to ensure long term planning and investment into sustainable material use and recycling infrastructure, and to fulfil the ‘polluter pays’ principle. From 2023, all producers will be expected to pay into the system and bear the full net cost (FNC) recovery of the packaging they place on the market.

Which types of businesses will be affected?

The changes will affect businesses that place packaged products onto the UK market, as they will have to pay 100% of the costs associated with dealing with packaging waste. Obligated businesses will fund both the collection and recycling of packaging waste; the former is currently funded by local authorities using money accrued from local taxpayers.

How do the reforms differ from current systems?

Under the current Packaging Waste Recovery Note (PRN) system, producers only have to fund the recycling of collected packaging, making it more affordable while still achieving national recycling targets. However, it is estimated that these contributions cover only 7% of post-consumer waste management operations in the UK. Under the reformed EPR regulations, producers’ compliance costs could increase 6-20-fold depending on the final design of the new system. Costs may further increase if businesses incur additional costs under the proposed Deposit Return Scheme and UK Plastic Packaging Tax.