Home Page Add to favourites Site map Contact member Area
Your Obligations |  A simple online compliance for producers of category 1-10.
  • Exploring the future of Extended Producer Responsibility

    24th Jul 2019

    REPIC CEO, Mark Burrows-Smith, shares his thoughts on the UK Government’s framework for EPR following the recent consultation.

    May saw the end to the consultation period for what could be a pivotal change for producer responsibility, ostensibly for packaging, but with possible implications for WEEE to come. The real game changer for producers being the implementation of full net costs – bringing into force Article 8a of the revised Waste Framework Directive.

    The consultation is extensive and not without some significant issues. Albeit relatively high level, with much detail no doubt to be added, there appears to be a basic inconsistency with equating EPR costs and fully funding aspects of local authority waste services.

    Any change has the potential to significantly increase packaging compliance cost for all producers, with some estimates suggesting a 10-fold increase over 2017 packaging compliance costs. The new packaging compliance regime is planned to be in place by 2023 but that remains open to change. 

    Admittedly, individual producers can and will seek to reduce their costs with better design and material choice, but ultimately producers are still expected to cover the full net cost of packaging-related local authority services. As an extreme, in a situation where all producers reduced the environmental cost of their packaging to the lowest extent possible through design and material choices, then the fixed costs of local government waste packaging collection infrastructure would still need to be funded. Where, therefore, is the incentive to innovate and reduce costs, if the fixed costs inherent in the system still exist? An unrecyclable material could, today, cost a producer the same amount in EPR fees, as a wholly recyclable material in the future. There is a risk that the system costs can never, under the consultation proposals, fall below the cost of local authority services.

    Whilst nobody can deny that the Packaging System is ripe for overhaul and current financing is far from fair and equitable, in moving the bookends of producer responsibility we need to understand where we move them to.

    Producers largely accept that they should pay the fair net cost of collecting and recycling packaging, but the producer’s role should not be relegated to just acting as a funder for Local Authority costs. The governance of EPR should be led by the producers who are funding that EPR system. This is something which is not explicit in any of the Governance models proposed.

    Defra should rightly be applauded for the ambition they have shown in the proposals they have put forward to address resource and waste management. However, they should beware unintended consequences. The EPR system and the final governance model should reflect fair net costs, protecting all parties against profiteering whilst producing quality secondary resources. Underpinning this is the requirement for appropriate measures to be put in place to:

    • lead to better environmental outcomes
    • develop a producer led, producer funded system that rewards those that deliver resource efficiency
    • increase market transparency, subject to competition law considerations
    • ensure costs to producers do not exceed those necessary to provide packaging waste management services in a cost-efficient way,
    • help all retail actors, be they bricks and mortar, or on-line, be fairly treated

    The ultimate goal is to produce consistent, high-quality, industry-ready, raw materials that support the UK economy and recycling industry, in order to be capable of competing for use on a global scale.

    « back to news