Extended Producer Responsibility (EPR) policy driving sustainable packaging

BY DAVID WRIGHT - PACKAGING TECHNICAL SPECIALIST 
6 January 2023

 

Both the EU and UK have set 2024 as the target for full compliance with their respective Extended Producer Responsibility (EPR) schemes. This gives food suppliers an added incentive to switch to more sustainable packaging. But how can you be sure these new packaging options are fit for purpose as well as compliant with Extended Producer Responsibility regulations?

 

Each jurisdiction tends to have their own variants of Extended Producer Responsibility regulations.  The latest Extended Producer Responsibility UK 2023 guidelines are published on DEFRA's website.

 

EPR schemes are designed to transfer the cost of collecting, reprocessing and recycling packaging to producers and importers, rather than local government authorities in the case of EPR legislation UK.

 

By EPR legislation shifting the responsibility, either fully or partially, it’s hoped that organisations across the retail chain will be motivated to use packaging that’s reusable and easy to recycle at the end of a product’s shelf life.

 

Given that most food packaging is single use, EPR has significant implications for the sector. Yet, although many of the food giants are already committed to sustainability and have been getting ready for the formal introduction of EPR regulations for some time, SMEs are arguably less well prepared.

 

 

But it’s important that every company, irrespective of size, gets to grips the new legislation. Failure to provide evidence - in the form of purchased Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs) - that an equivalent weight of packaging has been recycled is likely to result in a double financial hit; a fine for not submitting the relevant data plus a back dated bill for all the packaged goods supplied and handled from the beginning of 2023. 

There’s also an additional annual fee that companies must pay to the environmental regulator, depending on their turnover and total weight of packaging handled. And let’s not forget that EPR is in addition to the plastic taxes currently in force and refers to all packaging materials, renewable or otherwise. 


So it’s perhaps not surprising that some of these new costs may eventually be passed on to the consumer; adding as much as 0.6% to the average shopping basket according to some calculations. Such an increase is understandably cause for concern, particularly given today’s historically high inflation and cost of living crisis. However, there are ways to mitigate the impact of EPR.



Managing change

 

Using more lightweight materials, rather than rigid glass bottles and jars or metal cans and tins, is one option that’s also highly relevant for companies handling close to the EPR threshold of 500 tonnes of packaging per year. Although ‘light weighting’ has long been an effective strategy for reducing fuel and transport costs, it’s now taken on even greater significance in light of PRN costs and the need to reduce carbon footprint. 

Switching to recycled and biodegradable packaging materials is another important consideration. They are charged at a lower PRN rate than plastic which, as you would expect, is at the top of a rapidly rising price scale – again, underlining the fact that the EPR framework rewards sustainable packaging choices.


In practical terms, this means that a small beverage manufacturer, with a turnover exceeding £2 million, could potentially reduce annual packaging tonnage to a level that avoids EPR altogether. And if at least 30% of recycled plastic is used, it could also be exempt from the plastic tax.

At the same time, it’s important to recognise that making changes to packaging formats and/or materials may not be straightforward. More sustainable alternatives must still perform the same principal functions as the existing packaging. That is:

  • Protect the contents of the packaging after filling; during transport, storage and throughout shelf life right up to the point of consumption

 

  • Be compatible with the existing plant operation and machinery

 

  • Provide an easy to open and, in many cases, resealable mechanism

 

  • Advertise contents and required information to the consumer, such as ingredients lists as well as how the packaging should be recycled or disposed