Paul Empson, General Manager at Bakers Basco, examines how the UK Packaging PRO can ensure pEPR delivers environmental outcomes without hamstringing industry.
The government’s announcement that UK Packaging PRO has been appointed to deliver the UK’s Extended Producer Responsibility (pEPR) scheme marks a significant milestone in what is arguably one of the most ambitious environmental policy shifts we’ve seen in a generation.

An industry-led Producer Responsibility Organisation (PRO) has the potential to be a positive step forward.
Giving producers a genuine seat at the table should, in theory, ensure that those who understand the complexities of packaging systems are directly involved in shaping how pEPR is delivered. That collaborative approach is something I welcome.
However, while the intent behind pEPR is absolutely right – driving recyclability, reducing waste and accelerating the circular economy – the real test will be how this is implemented in practice.
From my perspective at Bakers Basco, I still have some of the same concerns I raised when the scheme was previously delayed.
Firstly, cost remains a critical issue. There is no doubt that pEPR will place additional financial pressure on businesses across the supply chain. While large organisations may be better equipped to absorb or adapt to these costs, smaller operators could struggle.
Even for established businesses, there is a fine balance between supporting environmental progress and maintaining commercial viability. Ultimately, those costs do not disappear; they are passed through the system, often landing with the end consumer.
At a time when businesses and households are already facing significant financial pressures, this cannot be overlooked.
Secondly, and perhaps more importantly, there is still a concern around how a scheme like pEPR fairly accounts for different types of packaging models – particularly reusable systems.
At Bakers Basco, our entire model is built around reuse. Our bread baskets and dollies are designed to remain in circulation for many years, supporting a circular economy long before it became a policy priority. They are not single-use items; they are assets that are repeatedly used, recovered and redistributed.
However, one of the challenges we have consistently highlighted is how schemes like pEPR deal with loss, theft and misuse. If reusable assets are stolen or diverted out of the supply chain – something we actively work to combat – they risk being treated within the framework as waste or recycling obligations, despite never reaching the end of their intended lifecycle.
That simply doesn’t reflect the reality of how reuse systems operate. If pEPR is to succeed, it must recognise these nuances. A one-size-fits-all approach risks unintentionally penalising the very systems that are already delivering strong environmental outcomes.
That said, the appointment of UK Packaging PRO does provide an opportunity to get this right. An industry-led body should be better placed to understand these operational challenges and work with the government to develop a more balanced and practical framework.
The fact that the PRO will work closely with PackUK, while still being held accountable, suggests there is scope for both collaboration and oversight – which is encouraging, but what we need now is meaningful engagement.
Producers, operators and organisations across the value chain must be actively involved in shaping how pEPR evolves from policy into practice. This includes ensuring that fee structures, reporting requirements and performance metrics genuinely reflect real-world operations.
We also need to see continued investment in UK recycling infrastructure. Without this, the ambition of increasing recycling rates and reducing waste will be difficult to achieve, regardless of how well the scheme is designed.
There is no question that the UK must move towards a more circular economy. The direction is clear, and rightly so, but success will depend on getting the detail right.
If pEPR is implemented with flexibility, fairness and a clear understanding of different business models, including reuse systems like ours, it has the potential to drive real, lasting change. If not, we risk creating a system that adds cost and complexity without fully delivering on its environmental promise.
The appointment of UK Packaging PRO is an important step forward. Now the focus must shift to ensuring the scheme works not just in principle, but in practice – for businesses, for consumers and for the environment.
