EPR is not a ‘recycling tax’, it’s integral to industrial strategy and a real opportunity to drive economic growth, John Twitchen writes.
The UK needs growth that creates skilled jobs, strengthens regional economies, and delivers better value for households and taxpayers.
Extended Producer Responsibility – or EPR – can help deliver it.
Too often, EPR is presented as little more than a way of making producers pay for recycling, but that seriously undersells its potential.
Well-designed EPR can encourage products that last longer, are easier to repair and safer to recycle. It can create dependable markets for recovered materials, unlock private investment and rebuild domestic capacity in manufacturing, repair, reuse, and remanufacturing – all clearly supporting the government’s ‘re-industrialisation of the UK’ aim.
EPR should be treated as part of the UK’s industrial strategy – not simply as a mechanism for paying waste and recycling bills.
The cost already exists
Critics frequently describe EPR as a ‘tax on consumers’, but the cost of dealing with discarded products already exists.
We all pay for it through council waste budgets, damaged recycling facilities, fire service call-outs, rising insurance premiums, environmental clean-ups, and the loss of valuable materials from the UK economy.
EPR does not create these costs. It moves them into the market responsible for the products – and gives producers an incentive to reduce waste, impacts, burdens and costs.
A durable, repairable, and recyclable product designed with end-of-life management considerations in mind should not attract the same fee as a short-life product that is difficult or dangerous to deal with. The costs should be different because the impacts are different.
That is where EPR becomes powerful. It can help rebalance the market from things that are cheap to buy towards products and services which offer good value over time.
From regulation to investment
The economic logic is straightforward:
- Clear rules create predictable producer funding.
- Predictable funding creates confidence to invest.
- Investment creates infrastructure, skills and jobs.
- Better infrastructure retains materials and value in the UK.
Businesses can invest in sorting equipment, repair centres, recycling plants and new technologies when there is a reliable market and a clear policy timetable. They are far less likely to invest when implementation dates keep slipping, rules of engagement change and revenues depend on volatile commodity prices.
The UK’s WEEE system already demonstrates this. Producer funding and treatment requirements have supported repeated investment in fridge recycling, display treatment, metals recovery, post-shred sorting and small electrical processing – and there’s more still to come.
The lesson is simple: create a dependable market framework, and industry will build the capacity to serve it.
Batteries: A burning issue
Batteries provide the clearest example of why reform is urgent. Not a week goes by without another report of a waste facility fire caused by, or suspected to have been caused by, a battery.
The current producer responsibility and collection system was designed largely around conventional portable batteries. It has not kept pace with the explosion of lithium-ion cells embedded in vapes, toys, power tools, personal electronics, e-bikes and countless low-cost devices.
Many cannot easily be removed. Consumers may not even realise a battery is present.
When these products enter household rubbish or mixed recycling, batteries can be crushed or punctured, triggering fires in bins, collection vehicles, transfer stations, recycling facilities and treatment plants.
The producer sells the product. The waste sector, councils, emergency services, insurers and taxpayers pick up the risk and the cost.
A modern battery EPR system should charge according to the real cost and risk of a product. Fees should reflect battery chemistry, removability, durability, repairability and fire risk. Leading industry figures are now supporting the call for a battery deposit return scheme, first set out in CIWM’s July 2024 report.
An updated EPR system for batteries should include:
- higher fees for unnecessarily embedded/non-removable batteries;
- deposit or similar return incentives, at the very least for high-risk products;
- producer funding for safe containers, storage and fire prevention;
- clear responsibilities for online marketplaces and overseas sellers;
- chemistry-specific collection and recovery targets;
- support for repair, refurbishment and safe second-life use; and
- better traceability for larger batteries.
This is not just about preventing fires. It is an industrial opportunity.
End-of-life batteries contain strategically important ‘critical raw materials’, including lithium, cobalt, nickel, copper, manganese and graphite. Recovering them domestically will support emerging domestic recycling specialists alongside skilled jobs, as well as strengthening supply chains and reducing dependence on imported raw materials.
Success should not be measured only in tonnes collected. It should include fires prevented, costs avoided, batteries reused, materials recovered and UK investment secured.
The social impact of batteries – the wrong waste in the wrong place – is currently a major negative cost. We have the opportunity to turn this into a major positive opportunity.
Textiles: From throwaway fast fashion to domestic industry
Textiles offer a second major opportunity.
Currently, the UK is literally importing tomorrow’s textile waste without any way of managing it.
The UK imports huge volumes of clothing while retaining relatively little capacity for domestic manufacture, repair, automated sorting or fibre-to-fibre recycling. The current system is on its knees, relying on charities and a dwindling number of private companies for textiles reuse and export.
Driven by fast fashion, volumes have risen dramatically while at the same time quality has plummeted. Export markets are being closed off. Complex blends, coatings, trims and short product lives make recovery harder. Producers currently face little direct financial consequence for placing low-quality or unrecyclable garments on the market.
A strong textiles EPR system should reward durability, repairability, reuse and recyclability. It should penalise unnecessarily complex, short-life products and transparently reinvest revenues in UK collection, sorting, repair and recycling infrastructure.
This is demonstrated by the EU scheme currently being implemented, alongside tightening requirements around eco-design.
Separate targets are essential. A single recycling target could pull wearable clothing away from reuse, even though reuse usually retains more value.
The system must also address exports. Genuine reuse exports can extend product life, but EPR should not subsidise the shipment of low-quality material that simply transfers waste-management costs overseas and out of sight.
CASE STUDY – Stuff4Life closing the loop
Stuff4Life demonstrates the type of domestic opportunity that effective policy could unlock. Its work on polyester depolymerisation aims to recover purified chemical feedstock from polyester-rich textiles for use in new material production. Chemical recycling is not a substitute for using less, making products last longer, repairing them or reusing them. It is the final part of a genuinely circular system for textiles that have reached the end of their useful lives. The Stuff4Life vision combines: ● durable UK manufacture of essential textiles; ● clothing supplied as a service; ● professional laundering and maintenance; ● repair and redeployment; ● high-quality sorting; ● fibre-to-fibre and chemical recycling; and ● recovered feedstock used in new products. Public-sector uniforms and workwear offer an ideal starting point. The NHS, defence, emergency services and councils buy textiles at scale and can specify durability, repairability, traceability, take-back and recycled content. For workwear, service-based contracts create an especially strong incentive. When a supplier remains responsible for issuing, laundering, repairing and recovering garments, making them last becomes commercially valuable. |
Procurement creates demand
EPR can create a dependable supply of reusable products and recovered materials. But supply alone is not enough.
Public procurement can create the demand.
Government purchasing standards can favour durable products, repair services, refill and zero-waste solutions, recycled content and circular supply models, alongside wider social impacts including domestic manufacturing.
It can do this while demonstrating better value for money and wider benefits when fully costed. Long-term contracts can give investors confidence that a shift to servitisation will be supported, and that recovered materials will have a market.
EPR creates the supply, procurement creates the demand; together, they drive innovation, support industries and create opportunities.
What government can do
The Government should publish firm timetables for reforming batteries and WEEE, and for introducing textiles EPR. The immediate publication of the Circular Economy Growth Plan (CEGP) should support this.
- Fees must genuinely reward better design;
- schemes should fund the full cost of safe collection, communications, infrastructure, enforcement and innovation;
- targets should cover prevention, repair, reuse and remanufacturing – not just tonnes collected;
- online marketplace loopholes must be closed, as is being done across the EU;
- regional demonstrator projects should connect circular economy investment with local industrial strengths and technical skills; and
- success should be measured through investment, jobs, public costs avoided, product life extended and recovered materials returned to UK production.
EPR alone will not create a circular economy. But it can create the stable funding and market conditions needed to build one.
The objective is not to charge consumers more for the same ‘disposable’ economy, driven by cheap poor-quality products, and the polluter producers getting away without paying… rubbish in, rubbish out.
It is to create a better, value-for-money economy – one in which products last and are repairable and recyclable, materials remain valuable, risks are properly managed, and the resulting jobs, skills and investment stay in the UK to help drive the move towards re-industrialisation.
To support the implementation of EPR schemes, CIWM has produced an EPR ‘toolkit’. This considers existing EPR advice, guidance, and best practice from around the globe to inform the development of policy and practice excellence. The toolkit can be accessed here.
