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5 Highlights from the EPR Consultation

The government recently released its consultation response, from the Department for Environment, Food, and Rural Affairs (DEFRA), on Extended Producer Responsibility for Packaging (EPR).


The release of government responses is always an opportunity to look at the bigger picture and hone in on its localised impact, both from a commercial perspective and from a local authority point of view.

As part of our recycling process, packaging, by default, is incorporated into our process, whether that’s via food waste, contaminated food packaging or even pet food products. So, the more producers are doing to combat this, the better and more economical it is further down the chain. As a business, we believe that knowledge is power and something that enables us to keep on top of the changes within our industry and how these changes affect everyone. So, having had some time to read, process, and digest, we’ve picked out our key highlights from the response.

Charges applied

In a bid to look after small businesses, those with a turnover of at least £2m and 50 tonnes of packaging will have to pay for the recycling of their packaging. Another threshold was set for those with a £1m turnover and 25 tonnes of packaging; whilst not obligated to ‘pay fees to cover disposal costs’, they will have to start reporting on the packaging they use. This is designed to raise awareness of the impact that their packaging has.

Do not recycle

Both biodegradable and compostable packaging will be labelled as ‘do not recycle’ and classed as non-recyclables for now. This will be until the infrastructure and evidence for compostable and biodegradable packaging improves and becomes more widely available.

Alongside this, there is to be a ‘mandatory labelling of packaging’ for recycling, using a single label format. DEFRA has agreed with WRAP on its use of the ‘Recycle Now’ mark, and only producers who are ‘required to label their packaging can use this mark’. All packaging (except for plastic films and flexibles) will be required to be labelled as ‘recycle’ or ‘do not recycle’ by 31st March 2026.

Support the process

Any money raised through the collection and management of packaging waste will be paid directly to the local authorities to cover the cost of recycling the packaging that ultimately ends up with residents. Essentially, ensuring that all households should be able to recycle packaging from home.

Any packaging disposed of by businesses, for example, on the high street or in offices, will be excluded for now as these are deemed too complex. The response also mentioned that many local authorities feel that the producer of the products should be responsible for the costs.

Deposit return scheme

Whilst the Deposit Return Scheme, which is helping to tackle waste drink containers, is still awaiting consultation, it was discussed that they would cover some packaging. This means residents have to take their waste back to the relevant machines placed by retail outlets and on high streets. However, other materials are planned to be covered by EPR, such as glass drinks bottles, via doorstep collections.

Mandatory take back requirement

In 2019 alone, around 3.2 billion fibre-based cups (disposable or single-use) were on the market. As a result, the EPR outlines a takeback requirement from sellers in a phased approach. In addition, the seller is required to have a dedicated bin, which will be in effect from 2024.

The EPR scheme will be implemented in a phased approach from 2024 and will be reviewed after two years. A task force is in place, and the government will be working closely with local authorities, the waste industry and management as a whole, as well as the manufacturers of packaging over the coming years.

“Over the last few years, there have been many consultations on the future of waste management, and we are all waiting with bated breath for Defra’s responses. It's great to see the EPR consultation response. Hopefully, after the May elections, there will be a flurry of Defra responses to the other consultations so we can see the big picture of how all the new schemes will work together to enable a giant leap forward in recycling and sustainable waste management across the UK.” 

Lee Dobinson - Chief Commercial Officer


Click to read the full EPR consultation response

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