Eunomia models litter costs for EPR payments

Eunomia has created a model to calculate the cost of dealing with littered items, to help “inform discussions” around the Extended Producer Responsibility (EPR) proposals.

The model comes ahead of the EPR implementation

The model, which was produced for resources charity Wrap, measures how the burden of costs associated with litter can be shifted from local authorities towards producers.

Proposed amendments to current UK EPR obligations would broaden the scope to include litter clean-up in producer obligations , as part of a ‘full net-cost recovery’ approach.

However, this would only apply to packaging and not other items such as chewing gum or cigarette butts.

Eunomia explained that its method will help determine the total cost of litter as a proportion of street cleansing costs, taking into account weight, volume and overall number of items.


The model’s general approach is to take the total street cleansing costs reported by each local authority and split the costs between eight components of cost. These are: people, equipment, vehicles, facilities, other (mainly monitoring),  disposal,  enforcement and education and communications.

Then, the method would need someone to estimate how much of each component is used for litter related activities, and then costs are attributed to specific litter categories, based on composition data.

The cost associated with litter for each component are then summed to produce the total costs associated with litter, including packaging.

“It feels really good to see the headway being made in the UK and the EU on getting the costs of litter redistributed more fairly in society.”

– Chiarina Darrah, Eunomia

Commenting on the model, Chiarina Darrah, senior consultant at Eunomia, said: “It feels really good to see the headway being made in the UK and the EU on getting the costs of litter redistributed more fairly in society. This will help get the right stakeholders round the table to do something about the problem. As most marine litter is terrestrial litter first, this is a really effective juncture at which to address it – on land!”


Overall, Eunomia estimated that packaging accounts for 58% of the total cost of litter, amounting to £384m.

This reflects that although packaging makes up a majority of litter by volume (85%), when count (42%) and weight (40%) are used to attribute cost for different components of litter provision, this brings the relative contribution down.

As staff time for picking ground litter is the largest fraction of cost, this leads to count-based composition influencing the percentage attribution more than the other units, the consultancy explained.

It said data on the issue would need to improve however, and some EPR payments should contribute towards this.

Producer costs

Eunomia explains that standardising how costs of litter are calculated “should support producer consensus on costs, which facilitates EPR roll out”.

It added that manufacturers should benefit from seeing that they are not getting overcharged for the costs incurred when their products are littered.

The consultancy said that the model can readily be applied beyond the UK and will be “particularly relevant” for EU Member States where the Single Use Plastics Directive (SUPD) requires litter costs for specific items to be covered by producers through EPR.


Billy Harris, senior analyst at WRAP, said: “This is an innovative piece of work that represents a major step towards understanding the cost of litter management to UK local authorities and other statutory bodies. It will play an important role in informing the debate around litter costs in the context of Extended Producer Responsibility.”

Useful links

Financial cost of packaging litter




Leave a Reply

The Blog Box

Other Publications from
The Environment Media Group

Back to top