It has been well over half a century since the grocer had a sugar cone on his counter along with a slab of butter which he would shape into a half pound portion with wooden paddles before your very eyes. Biscuits were displayed in large boxes with glass tops and you could buy as many as you wanted; sweets too. Pop came in returnable stone-stoppered bottles and was delivered to your door by the Corona man and water only came out of the tap. Dust bins cannot have been very full in those days when the bin men used to come round to your back yard to empty them.
Now we are knee deep in plastic, one trip glass and cans. You can buy a solitary banana in an expanded polystyrene tray wrapped in cling film and single serve pouches made from layers of different plastic materials which make recycling currently impossible. Any plastic recycling that does take place needs rigorous sorting and even then will most likely end up in non-food products. Much of course goes to landfill and overseas, handing the problem of disposal on to somebody else.
Apparently I have a teaspoonful of microplastic embedded in my brain which is somewhat alarming and heaven knows what the even smaller nanoplastic particles are doing to us. Plastic is derived from fossil fuels and takes an age to breakdown but it is lightweight and keeps food fresh so it cannot disappear overnight. Then along comes the UK Government with EPR – Extended Producer Responsibility which is supposed to get us all to use products with less encapsulating packaging.
This will be on top of the Plastic Packaging Tax introduced in 2022 where suppliers pay £200 a tonne for plastic put into the supply chain which contains less than 30% recycled material. Even though users do not pay the tax, they have to keep records of packaging used. This imposition aims to cut down on waste, encourage recycling and perhaps users would also use less. Half of the UK’s five million tonnes of plastic used annually is packaging.
The introduction of EPR from April 2025 is a major policy shift aimed at reducing the use of one trip packaging which ends up in our dust bins. It aims to cut down waste and improve recycling, but it will shift the financial burden of household waste management from cash strapped local authorities to producers and brand owners. While the policy is ambitious and environmentally motivated, it also raises a number of challenges and will undoubtedly push up prices for the consumer.
Under EPR, producers will be responsible for the full net cost of collecting, sorting, and recycling packaging waste from dust bins, kerbside collection, bring banks and even litter bins. This will significantly increase costs, especially for small and medium-sized enterprises. An earlier system – the Packaging Waste Regulations was introduced in 1997 where each invoiced SKU had an associated weight of glass, metal, wood and card. An annual total was then netted off against PRNs – Packaging Return Notes which were purchased from material recyclers.
There were a number of packaging waste compliance schemes but recently it was estimated that these arrangements only covered some 7% of the £2.7 billion cost of dealing with what the nation throws away. With the supply industry now faced with 100% of those costs, we are told that beer in a 500mL glass bottle will cost a further 8p to cover it. With small margins, a competitive market and cost conscious customers it is hard to see how the supply chain can absorb the new ‘tax’ and its effect is bound to be inflationary as producers will pass these costs on to consumers leading to higher retail prices. Businesses too must report detailed packaging data and manage compliance, which can be particularly burdensome and costly for smaller firms.
There are complexities in defining who qualifies as a ‘producer’ especially in long supply chains or for imported goods. Responsibility depends on a business’s size and how much packaging it handles. The government defines these as small or large organisations. Small firms turn over £1-2 million and supply up to 50 tonnes of packaging into the UK market. Such producers will only need to report packaging usage but can expect larger invoices as the packaging supplier will be responsible for purchasing PRNs and paying EPR fees. Large businesses turn over more than £2 million and produce over 50 tonnes of packaging. These will be liable for purchasing PRNs and other fees/costs associated with packaging recovery and recycling as part of the EPR. Thus, a supplier of packaging material will need to define which customer is which. They are liable for all apart from the large users that own the brands which the consumer buys. An added complication is that reporting is for calendar years rather than financial years.
Apart from the imposition of added costs, the main issue in the drinks industry is the hospitality sector where waste from pubs and restaurants is already collected on a commercial basis by the likes of Biffa and Veolia where it is put into existing recycling schemes so do not end up in a household dust bin. There is a big risk of double counting and the industry will be paying for millions of phantom bottles which the local authority is never going to have to handle. There is similar risk of undercounting and widespread mis-accounting (by error or fraud) as the whole system will inevitably be very complicated. The government says it will take two years to sort out these nuances but the first bills are expected this autumn.
So, a slab of 24 cans with tray and shrink wrap could be sold to a supermarket where the pack will be stripped, with the card and plastic going into a commercial stream while only a sale direct to a household will result in a cost of disposal which EPR is designed to cover. EPR fees will not be applicable to transit packaging, which is mainly a covering that is used to transport goods in B2B applications. For example, stretch wrap used to stabilise pallets is handled in the warehouse as commercial waste where PRNs will still have to be collected, while plastic bakery trays, kegs etc. do not count as there is a circular recovery system in place.
This half thought out strategy has led WSET to deem it a joke with the wine and spirit sector desperately seeking to get the charge for glass reduced. The system is based on weight, meaning that glass is charged at seven times that of lighter but more environmentally damaging plastics, which fill your brain with tiny bits. Glass, because it is relatively heavy will be much more expensive to use under the current EPR regulations. Lightweighting has probably gone as far as it can without the bottles becoming dangerous, so drinks companies are already looking for lighter weight alternatives. Some 80% of glass is already recycled so lobbying is taking place to make sure that glass is excluded from the putative Deposit Return Scheme (DRS) as well.
DRS is separate and will see a charge being put on non returnable containers. While plastic and metal are certain to be included, we understand that the glass industry is seeking to remain with standard kerbside and bring-bank collections. As consumers we will pay an extra charge (probably 20p per item) at point of purchase. We will all be expected to take the empty container to a ‘reverse vending machine’, at retailers’ and other sites, to reclaim the deposit. These machines cost £30,000 plus £2,000 for installation and are not really designed for high volumes and weight of glass bottles. A Scottish DRS, which currently includes glass, has been delayed to coincide with an introduction south of the border in 2027. Whether you get your deposit back in cash or token I know not. What I do know is that whisky in an aluminium can, even if you could reseal it, would not be very popular.
The Food and Drink Federation is a bit more supportive saying if the scheme is implemented properly it could help the UK develop a world-class recycling system and circular economy for packaging which would be of benefit to all of us. The government must ring fence the billions raised through EPR to be spent improving recycling rates and not simply used to plug shortfalls in council budgets. The industry paying this tax will have no say in the efficiency at local authority installations where we are already aware that there are wide differences across the country.
Businesses are charged with appointing a systems administrator to handle their obligations and should be collecting data from April without knowing what the fees will be for each type of material they are supposed to be using less of. It is incredibly hard to try to do business now without a pricing strategy for the future.
There is no issue with the logic of EPR. The three individual EPR, PRN and DRS need to consolidated in a way that makes sense. Currently we suspect there is not the infrastructure in place for aluminium and plastics to be recycled on the scale needed to keep pace with what EPR demands.
While EPR for one-trip packaging in the UK is a step toward a circular economy, its success hinges on resolving practical, financial and infrastructural challenges. Careful implementation, transparent oversight and support for smaller producers will be key to ensuring it achieves its environmental objectives without creating an undue burden.
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