Alice Rackley, CEO of Polytag, explains that the future of Extended Producer Responsibility won’t be defined by how much packaging that’s collected, but by how value is recovered.
The government’s decision to press ahead with Extended Producer Responsibility (EPR), despite calls from brands and retailers to delay or rethink the scheme, is a turning point for the UK’s packaging industry.
Whether businesses agree with every aspect of the policy or not, EPR is now moving from consultation rooms into reality. The conversation is shifting from whether producer responsibility should exist to how we make it work, and that question arrives at a particularly interesting moment.
Recent figures suggest the UK has lost around 22% of its plastics recycling capacity in the past two years, while policies including EPR, Simpler Recycling and the forthcoming Deposit Return Scheme are all designed to increase the amount of material entering the recycling system.
In other words, we are asking more of the UK’s recycling infrastructure than ever before. But beneath the debate around fees, targets and compliance sits a more fundamental challenge: we still struggle to prove what happens to packaging once it enters the waste stream.
That matters because the future of circularity will be defined not by how much packaging we collect, but by how much value we recover.
Collection is only half the story
For years, success in recycling has largely been measured through collection rates. Collect more packaging, increase recycling volumes and divert more material away from landfill. Those are important goals, but they only tell part of the story. The bigger question is whether that material is actually recovered at value.
Today, brands face growing pressure to incorporate more recycled content into their packaging. The Plastic Packaging Tax has accelerated that demand, while consumers increasingly expect businesses to demonstrate genuine environmental progress.
Yet at the same time, high-quality post-consumer recycled plastic (PCR) remains scarce. That should tell us something. If collections alone were the answer, the industry would not be facing ongoing challenges securing packaging-grade recycled material.
The issue is not simply how much material enters the system; it’s what happens to that material once it gets there.
If plastic packaging cannot be accurately identified, separated and recovered at the right quality, much of its value is lost. Material that could have become a new bottle, tray or food-grade container is instead downcycled into lower-value products or removed from the circular economy altogether.
This is where many conversations around EPR are missing the point. The success of the policy will not ultimately be measured by how much packaging enters the recycling system, but by how much of that material returns to the economy as high-quality recycled content.
A new era of evidence
Historically, one of the biggest obstacles to achieving that has been visibility. Brands know how much packaging they place on the market. Local authorities know how much material they collect. Recyclers know what arrives at their facilities. But historically, there has been remarkably little visibility into what happens in between.
The recycling industry has often relied on estimates, sampling and assumptions. That has made it difficult to verify recycling outcomes, optimise material recovery or confidently reward packaging formats that perform well in real-world recycling environments.
What’s different today is that we finally have the technology to change that. New traceability solutions are enabling packaging to carry a digital identity throughout its lifecycle.
Invisible UV ink tags applied to packaging labels can now be detected at scale within recycling facilities, providing brands with unprecedented visibility into how and where their packaging is entering and moving through the recycling system.
Crucially, these easy-to-apply UV ink tags can also carry information about packaging that cannot be observed from the pack itself. While visual detection technologies installed in MRFs can identify what an item appears to be, digital tagging provides access to the underlying characteristics that determine how that material should be handled within the recycling process.
For example, a recycling facility may be able to identify a polypropylene food tub, but not whether it was injection-moulded or thermoformed. It may recognise a milk bottle, but not which upstream dairy packed it for the brand.
Equally, attributes, such as polymer specifications or recycled content levels, are not visible once packaging enters the waste stream, despite their importance to material recovery and recycling outcomes.
As recycling systems become more sophisticated, access to this richer layer of packaging data will become increasingly valuable.
By connecting physical packaging to detailed product-level information, traceability technology creates a far more complete picture of the materials as they move through the system and ensures that critical information is not lost at the point of disposal.
The result is something the industry has never had before: evidence robust enough to truly optimise recycling outcomes, and ultimately drive a more effective circular economy.
This is already happening in practice. Retailers, including M&S, Waitrose and Ocado, are using packaging traceability technology to gain a better understanding of what happens to their packaging after disposal. Instead of relying solely on recyclability claims, they are beginning to access real-world data on recycling outcomes.
As a result, the conversation is moving beyond whether packaging is theoretically recyclable and towards whether it is actually being recycled in practice.
A glimpse of the future at Avonmouth
Perhaps the clearest example of where the industry is heading can be seen at SUEZ’s Avonmouth materials recovery facility.
The site is the first facility in the world to combine UV packaging detection with advanced sortation and material processing technologies. That may sound technical, but the implications are profound.
For the first time, the industry can both detect and act on detailed packaging information at an industrial scale. Detection technology identifies tagged packaging as it enters the facility, while integrated sortation systems use that information to actively separate material into defined fractions optimised for higher-value recycling outcomes.
Together, these technologies create the most detailed view yet of what is happening inside a recycling facility. But more than that, it’s a move from simply observing the composition of the waste stream to actively optimising how it is processed based on the underlying characteristics of the packaging itself.
For recyclers, this creates opportunities to improve material recovery and produce higher-quality outputs. For brands, that means access to a level of insight that simply wasn’t possible a couple of years ago. For policymakers, it provides something equally important: data robust enough to inform the next generation of policy decisions.
What comes after EPR?
That matters because EPR is unlikely to remain static. Like many producer responsibility schemes around the world, it will evolve as better evidence becomes available.
Today, producer responsibility frameworks are largely based on what companies place on the market. Tomorrow, they could increasingly take into account what happens to that packaging after it has been used.
As richer data becomes available, the government will have the opportunity to explore enhanced EPR incentives that reward proven recycling outcomes rather than relying solely on assumptions about recyclability.
Brands would be encouraged to invest in packaging formats that genuinely perform within recycling systems. Recyclers would have reason to invest in advanced infrastructure. More high-quality recycled material would remain within the UK economy, helping address shortages of packaging-grade recycled plastic.
And the benefits would extend beyond environmental outcomes. Greater investment in domestic recycling infrastructure would support jobs, strengthen supply chains and help build a more resilient circular economy at a time when demand for recycled content continues to rise.
From recycling targets to recycling proof
The packaging industry has spent years discussing circularity. The next phase is all about proving it.
As EPR comes into force and pressure grows to increase recycled content, reduce waste and improve resource efficiency, data will become one of the most valuable resources in the entire recycling system.
Not because data is an end in itself, but because it allows us to answer the questions that have long sat at the heart of the circular economy: What happened to this packaging? Was it recovered? Did it retain its value? Did it become packaging again?
We are now moving from assumptions to answers. And that may ultimately prove to be the most important development in UK recycling for a generation.