Extended Producer Responsibility (EPR) emerged as a concept in the 1990s when it was formally introduced in a report to the Swedish Government. The core idea behind EPR is to make manufacturers accountable for the entire life cycle of their products, including take-back, recycling, and final disposal, in order to reduce the overall environmental impact. By incorporating the estimated environmental costs upfront into the market price, EPR ensures that producers bear the responsibility for the environmental impact of their products.

Implementing an EPR strategy involves calculating all the environmental costs associated with a product, such as transportation footprint, packaging waste, and disposal, and factoring them into the market price. For instance, in the case of cars, where the environmental impact spans the entire lifecycle and includes reclamation costs at the end, an EPR approach would hold the manufacturer responsible for these expenses.

How will it help?

The advantages of EPR can be viewed from two perspectives, benefiting the wider community:

Shifting the cost burden: Under EPR, the costs associated with waste disposal and recycling, typically funded through local or national taxation, are transferred to the producers. While the methods for managing waste, such as rubbish collection and recycling centres, remain the same, it is the producer who covers the expenses instead of the taxpayer.

Driving design improvements: EPR incentivizes manufacturers to make design changes that can lead to significant benefits. Manufacturers have the greatest control over product design and marketing, giving them the ability to reduce toxicity and waste throughout a product's life cycle and at its end. This has been observed in the reduction and redesign of outer packaging, as producers anticipate covering the costs of waste and take-back responsibilities.

The key changes

The key changes introduced by the legislation include:

De Minimis: Small producers with a turnover exceeding £1 million per annum and handling over 25 tonnes of packaging are obligated to report branded packaging placed on the market.

Full Net Cost Recovery: Producers, rather than the taxpayer, cover the full cost of collecting, sorting, recycling, and disposing of household packaging waste. The government is developing a calculator to illustrate the increased costs for businesses.

Household Packaging: The extension of Full Net Cost to kerbside recycling specifically applies to household packaging waste, generated by households or similar entities.

Single Point of Compliance: The existing Packaging Waste Regulations' shared responsibility approach will be modified, shifting the cost obligation to brands, distributors, and importers who have a greater influence on packaging choices.

Modulated Fees: Starting from 2025, producers will pay fees based on the environmental and recycling qualities of their products, considering factors like recyclability. This requires more detailed data on packaging materials than the current system demands.

Detailed and Frequent Data Reporting: To support modulated fees, businesses will need to provide more comprehensive reporting on packaging recyclability, including details on packaging function, waste stream, packaging components, recycling disruptors, recycling enablers, format, and colour.

What does that mean in practice?

In practice, the UK has already implemented EPR through new legislation that came into force in 2023. These regulations extend the existing Packaging Waste Regulations and shift the responsibility for collecting household packaging waste from the taxpayer to producers. The desired outcome is to establish a more circular economy for packaging, where more recyclable waste is transformed into valuable secondary resources.

Exact details of how the new legislation will be introduced are still being finalised, but you can find details on EPR at the Government website in full here:

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