The real impact of Extended Producer Responsibility


Extended producer responsibility

Julien Tremblin, General Manager for TerraCycle Europe, explains how Extended Producer Responsibility will improve circularity in packaging.

After years of conversations, consultations, and a certain number of delays, it feels like momentum around waste and packaging in the UK is finally building up, with Simpler Recycling rules planned from 2026, and – crucially – the incoming implementation of the UK’s long-awaited Extended Producer Responsibility (EPR) for packaging.

As manufacturers up and down the country are now scrambling to produce their first sets of packaging data to satisfy the regulators, it is essential to look back at why the upcoming EPR is to be welcomed and why – once fully implemented – it could drive significant changes in the way the UK thinks about end of life for packaging.

So what role can this new EPR play, how will we measure its success, and will it truly improve circularity in packaging waste? Let’s dive in.

Extended Producer Responsibility: What will be its real impact?

Extended producer responsibility

Let’s first remind ourselves of all the reasons why EPR is to be celebrated and why getting it right is such a complex process. At its heart, efficient EPR legislation should lead to several positive developments.

The first is the creation of new and substantial financial flows that can foster innovation and infrastructure development in UK Material Recovery Facilities (MRFs) and recycling centres. For comparison in France, nearly 1 billion euros is now raised every year by EPR administrators, which helps support MRFs in more efficient sorting for valuable materials.

The second is how it will incentivise the switch to more recyclable materials through modulated fees. In essence, the easier the packaging is to handle – and the more valuable it is – the less it will cost a manufacturer to bring it to market. Reversely, complex or over-packaged goods will lead to higher fees.

An EPR scheme can also directly reward the use of recycled materials by offering discounts to companies that use a higher percentage of recycled content in their products and primary packaging.

EPR fees can be ring-fenced to help ensure better collection and recycling for materials that are currently considered to be “non-recyclable”.

Finally – and most crucially – part of the money raised from EPR fees can be ring-fenced to help ensure better collection and recycling for materials that are currently considered to be “non-recyclable”.

An example of this could be direct investment into initiatives such as those that TerraCycle runs on recycling medicine blister packs or coffee pods at scale, helping to make the economics work for recyclers.

A first encouraging sign is that the government plans to allow manufacturers, brands, and retailers to recoup some of their EPR costs if they fund or operate their own collection and recycling for hard-to-recycle materials.

Such initiatives prove that the government has its priorities right and truly wants to ensure better outcomes for packaging and reduce the amounts sent for incineration at home and abroad.

EPR is not a silver bullet

Silver bullet

However, we have to recognise that whilst EPR will be a step in the right direction, it should not be seen as a silver bullet that will fix all packaging woes and fully change the UK’s economy to be fully circular in a few years. The first consideration is the sheer amount of time that the implementation and subsequent investments will take.

France is currently leading the way when it comes to EPR and has the most advanced legislation in Europe with 17 product areas now falling under producer responsibility and requiring EPR registration.

But despite that and nearly 10 billion pounds of funding over the years, it took the country 12 years to upgrade sortation capacity across all MRFs in France. This new sortation helps MRFs sort more efficiently ensuring the capture of more PET bottles or aluminium cans.

This is because EPRs only tend to improve recycling outcomes for some of the simpler (or easier to recycle) packaging types. I mentioned earlier that the key objective is to make the economics work for recyclers but EPRs usually focus their attention on the most valuable packaging.

Funding from a future UK EPR may lead to improvements in the recycling of mono-layer transparent flexible films but will do little to address the myriad of complex or contaminated packaging currently on the market. Two key examples illustrate that:

  • Germany has one of Europe’s highest recycling rates partly thanks to its EPR and deposit return scheme (DRS) systems. However, it still only recycles 43.3% of its plastics. 
  • The French EPR system Citéo has led to the development of better recycling capabilities for polypropylene. However, little to no progress has been made for make-up packaging, medicine blister packs, or pet food packaging which will continue to require separate initiatives to be effectively collected and recycled for years to come. 

Another prerequisite is that EPR funding must be ring-fenced to have the intended effect. Targets and objectives must be matched with guaranteed and increasing levels of funding to create certainty for the industry and foster innovation.

For example, when it comes to pushing reuse, the French EPR system now must spend a minimum of 5% of its yearly income on directly supporting the government’s reuse targets, which will lead to a more circular economy for packaging.

This is one of the key reasons why France is leading the way and why our Loop reuse initiative is currently live in more than 150 Carrefour stores and developing with other retailers, supported by industry initiatives and government targets. 

We must remain vigilant to one of the pervasive effects of EPR.

Finally, we must remain vigilant to one of the pervasive effects of EPR. In principle, modulated fees are meant to help push manufacturers towards more circular packaging. However, charging more can lead to brands and retailers expecting more for their existing packaging instead of switching.

An example of this is seen in France, where the French EPR system has invested in polystyrene yoghurt pot sorting and recycling, instead of the originally intended objective of seeing brands move to PP or PET.

While we fully welcome the incoming implementation of the UK’s EPR for packaging, we should enter the next few years with our eyes wide open. Of course, it will improve outcomes and should lead to higher recycling rates as EPR supports the sortation and recycling of more and more plastic bottles and trays.

But we must continue to work today on solutions to effectively recycle many of the types of packaging that we all use daily from blister packs to coffee pods or make-up packaging and continue to push recycling rates across the board.

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