02 August 2023

The cost of the EPR delay

The cost of the EPR delay image
Image: S.SUPHON / Shutterstock.com.

Steve Palfrey, chair of ADEPT’s Waste Group, looks at the implications for local authorities of the delay in implementing extended producer responsibility (EPR).

Extended producer responsibility (EPR) for packaging waste is the cornerstone of the Government's Resources and Waste Strategy (2018).

It’s intended to drive a step change in recycling performance by requiring producers to pay the full costs of dealing with the products they sell. More fundamentally, it aims to make producers rethink their packaging both to minimise waste and to ensure that it is readily recyclable.

EPR is a great example of the polluter pays principle, requiring producers to consider the full life cost of dealing with their products and providing a direct, financial incentive to minimise resource consumption by design. We know our current usage of finite resources is unsustainable and as the global population increases, we urgently need to find ways to live within our means. That makes EPR an important driver of the circular economy, itself a key part of the Government's 25 year Environment Plan and one of the UN’s 17 Sustainable Development Goals.

Once in place, EPR will introduce modulated fees for producers, paying more for complex packaging and materials that aren't recyclable and minimising the cost of easier to recycle formats. Funding from producers is intended to drive wholesale improvements in recycling performance. Payments will flow to local authorities who will in turn be required to collect and sort all recyclable materials as part of a consistent nationwide collection and recycling service. As the scheme will cover imported materials as well as online sales, producers of all packaging placed on the UK market will pay.

As councils across the country will need to significantly increase their recycling services, EPR payments will provide more funding for local authorities, which in turn means more investment in green jobs and infrastructure, better recycling rates and improvements in UK resource security.

Local authorities have been expecting and planning for the introduction of EPR since the 2018 strategy was released and have responded to two consultations from Government in 2019 and 2021. However, continued delays are having real impacts.

Plans for improving local recycling services have stalled since 2021 while councils wait for further details around consistent collections, new burdens such as food waste, and clarity on funding. Investment in new vehicles, bins and infrastructure improvements is on hold as a result, and when consistency guidance and new funding are finally made available, there’s a real risk of supply chain bottlenecks as authorities across the country chase the limited supply of bins, trucks and processing equipment.

Although we are disappointed, time was getting increasingly tight for the scheduled EPR implementation in October 2024. What we need now is for this extra time to be used to best effect. ADEPT would like to see a clear transition plan, providing certainty to councils, waste management companies and producers, so that we all understand how the funding and service improvements will be implemented in a cost effective and coordinated manner. We can’t have a big announcement providing funding at short notice accompanied by an unrealistic implementation deadline. The lead times for most vehicles are already over 12 months, and that's before everyone races to place orders for new trucks.

It has been argued that EPR will be inflationary and shouldn’t be done in a cost of living crisis. While EPR will increase the costs of packaging we are talking a fraction of a penny per unit. And this is exactly the point of EPR – it’s about producers playing their part. At the moment the wider environmental costs and consequences of dealing with packaging – whether it’s collected as waste or it’s litter and pollution like plastics in the ocean – don’t show in the producers’ bottom line. EPR will give them a very tangible reason to minimise packaging and to fund, expect and contribute to better recycling services, minimising the amount of waste sent to disposal or littered.

As place directors we manage the consequences of packaging on a daily basis: we want to see producers put their energy into a shift to more sustainable packaging formats – minimising their use of resources will minimise their costs. It’s better for the environment locally and nationally. Don’t we all want that?

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