Defra urged to ‘re-think’ business waste plans

Defra’s proposals for the collection and funding of packaging recycling from businesses in England have been slammed in an open letter sent to the environment secretary, George Eustice. 

The letter sent yesterday (1 June) says there is concern that the three payment options for the management of business packaging waste in the extended producer responsibility (EPR) consultation “are not sufficiently developed to be implemented in the proposed timeframes”, and risk increasing costs to consumers.

Whoever controls the scheme will set a per tonne rate for commercial recycling collections, with rebates given for packaging

The letter was co-ordinated by the Environmental Services Association (ESA) and countersigned by 12 national organisations representing the retail, manufacturing and packaging sectors.

This includes the Food and Drink Federation, the Industry Council for Packaging and the Environment, the British Retail Consortium and the Recycling Association.

It calls on Defra to consider new ways to increase business waste recycling and expresses concerns that the current options are “too complex”.

The ESA also said they could drive unintended outcomes, including inflating costs to consumers.

‘Overly complex’

The executive director of the ESA, Jacob Hayler, stated that while industry is supportive of the ambition in Defra’s waste reforms, any additional costs need to drive recycling directly.

He said: “Alongside the many organisations which countersigned our open letter to the Secretary of State, we are concerned that Defra’s current set of options around EPR payments are overly complex and may drive undue costs or other undesirable outcomes.

“We are concerned that Defra’s current set of options around EPR payments are overly complex”

Jacob Hayler, ESA

“To simplify things and drive performance, not paperwork, we recommend extending local authority waste services to micro-businesses that create household-like waste in the short term, and to establish a specific work-stream to investigate and design more simple reforms that extend to business waste producers more widely.”


In the March 2021 EPR consultation, Defra set out three payment mechanisms for the controversial system, which the department estimated to cost around £1.5 billion.

The system will see businesses receive rebates, funded by producers, for packaging waste collected in order to bring the costs as “close to zero as possible”, and in turn drive recycling rates.

Defra provided three payment mechanisms in the consultation: ‘a scheme administrator system’, a ‘compliance scheme led payment mechanism’ and a ‘compliance scheme-led free bin approach’.

Some in the industry immediately expressed shock at the system (see story).


In yesterday’s letter, the signatories called for a post-consultation work-stream “dedicated to refining workable proposals”.

It says focusing first on delivering consistency of collections and EPR for households and micro-businesses is the “optimum way to deliver quick recycling performance improvement”.

The letter reads: “The government rightly aims to drive up recycling rates from non-domestic settings, but the three options presented for consultation highlight the complexity of achieving this. The current proposals contain many sound principles but attempting to accommodate the plethora of current business arrangements has created some highly complex policy proposals we believe may undermine the objectives of EPR.”

Although the consultation closes on Friday there is an expectation that Defra will not opt for any of the three options and instead consider a more hybrid approach.

The letter was copied into the recycling minister Rebecca Pow, as well as Chris Preston, Defra’s deputy director for resources and waste.

A full list of those who countersigned the letter:

  • Tom Giddings, general manager, Aluminium Packaging Recycling Organisation (Alupro)
  • Charles Jarrold, chief executive, British Printing Industries Federation (BPFI)
  • Jon Clark, general manager, British Printing Industries Federation
  • Graham Backhouse, general manager, British Printing Industries Federation
  • Nadiya Catel-Arutyunova, sustainability policy adviser, British Retail Consortium (BRC)
  • Simon Weston, director of raw materials, Confederation of Paper Industries (CPI)
  • Ian Wright, chief executive, Food and Drink Federation (FDF)
  • Martin Kersh, executive director, Food Service Packaging Association (FPA)
  • Paul Vanston, CEO, Industry Council for Packaging and the Environment (INCPEN)
  • Robert Fell, director and chief executive, Metal Packaging Manufacturers Association(MPMA)
  • Dick Searle, chief executive, Packaging Federation
  • Simon Ellin, chief executive, Recycling Association

Useful links
Open letter re maximising the impact and effectiveness of the packaging reforms.

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