12 May 2021 by Steve Eminton

‘Big chance’ to shape EPR, DRS and Consistency

Stakeholders involved in the consultations now underway on EPR, DRS and Consistency might not get another chance to change the system for 25 years, a packaging compliance expert warned today (12 May).

Addressing the letsrecycle.com conference on the consultations around Extended Producer Responsibility, Deposit Return Schemes and Consistency in local authority collections, the 25-year message came from Adrian Hawkes of Valpak who emphasised the importance of responding to the consultations.

He pointed out that the current system for producer responsibility in packaging has been operating for 24 years already. “It has done a lot of very positive things but a number of issues have emerged and it’s not surprising there are areas for improvement. The consultations might be the last chance we get to change the system for another 25 years.”

Clockwise from top right: David Bellamy, FDF; Stuart Hayward-Higham, Suez UK; Kate Ballard, business development manager, Clarity; and Adrian Hawkes, Valpak

He explained that the system is being “redesigned to make producers financially responsible for 100% of the costs associated with post-consumer packaging waste management”. But he warned that while consumer communications have been a bit of a lost subject in the past,” if we don’t get this message over to consumers the system won’t work so this is a key part”.


Mr Hawkes said that while the timetable has slipped slightly with a phased approach from 2023 to 2024 and beyond, major changes will come at the start of 2023. It will cover all packaging but large amounts would be taken out by the DRS.

Looking at the point of compliance, he commented on who will responsible for picking up the financial obligation and costs which is likely to be brand owners and sellers.  “A key point is, yes responsibility is changing to a single point but even if that point is not your business, you will be effected by EPR as pressures on costs move up and down the supply chain”.

A perspective on the new system costs (source: Valpak)

Raising the topic of costs which soar under the proposed new system, he said that the last couple of years have seen the highest costs in PRN system, £366 million in 2019. But, under the new system, said Mr Hawkes, “£2.7 billion is coming down the line, it’s absolutely a huge change. It doesn’t end there, the way the costs are allocated is absolutely critical. Last year there was a £230 million cost, an average of £19 per tonne.

“Under EPR it could be 13 times for current costs. Brand owners will have 100% responsibility for some of that packaging, and for some it could be 35 times the current costs.”

On who runs the new system, he said that there were two options and neither would make difference to local authorities. He recommended a combination of the two options with some functions held centrally alongside a strong role for competitive resources to make sure the producers get best value for money.

Waste composition

Next to speak in the conference session was Stuart Hayward-Higham, technical development director at Suez UK who, commenting on waste composition, said this isn’t static, pointing to the different types of authority and other factors such as holiday seasons. “Typical waste compositions don’t exist. Changes also happen depending on what is placed on the market – eg paper bottles and it is likely DRS will accelerate that.”

Mr Hayward-Higham predicted that for the changes, there will be a transition of between 3-5 years which starts around October 2023 with business waste in 2024/25 and this will be complete “somewhere between 2027/28 and 2030/2031”.

2026 could be the peak year for change under the Consistency proposals, said Stuart Hayward-Higham of Suez

For local authorities and consistency, he said that Suez had looked at collection and treatment contracts, vehicle fleets and DSOs  and saw the peak year for change in 2026, with large urban local authorities struggling to convert before then.

Core materials at the kerbside will change. On glass, the Suez expert said: “If glass is included in the DRS where there are 1,340,000 tonnes of single use beverage containers, DRS would take about half. EPR would be left dealing with jam jars and some bottles and others such as nail varnish. You could look at the headline 50% removed but it would mean that the glass left in the kerbside could have a higher propensity for contamination and there is a drive for quality.”


Representing some of the businesses likely to be hit by costs, which they can pass on to consumers, David Bellamy, senior environment policy manager, from Food and Drink Federation (FDF) gave some early perspectives.

He said the FDF supports the need for reform and that” it is essential that all the different policy elements join up to create one holistic policy, aligned across the UK.

“It is essential for industry to see a better system, one that is both more efficient and cost-effective and which overcomes current shortcomings, such as a lack of transparency and infrastructure investment, need for more consistency. Plastic films and flexibles should be included from local authorities from 2023.”

Plastic film: local authorities should collect from 2023, said David Bellamy of the FDF

The core concern from the FDF emerged as the likely costs. Mr Bellamy declared: “The most immediate thing that has struck home with our members is the uplift in costs to £2.7 billion up from £1.5 billion and some are also potentially open ended and there are concerns also about litter costs.”

In terms of the most costly element it will be business waste payments, he said. “They are up to £1.5 billion per annum and they have risen exponentially and seem to have been down to a much broader interpretation of ‘household-like’. Government can’t distinguish between household waste and commercial waste – We are seriously looking at if there is a better cost effective way of dealing with business waste.”

On obligations, Mr Bellamy said the FDF had supported the current shared approach under the PRN system “as it engenders cooperation and spreads costs along the value chain. We would still like to advocate the shared approach but obviously more unrealistic as the government has put forward.”

And, in a suggestion which might not be welcomed by all, he said if there were to be a single point, it might be “moving it to the retail end of the chain as this is closer to consumers.”

“Litter payments are a big area of concern: this is very open-ended in terms of payments”

David Bellamy, Food and Drink Federation

As with other speakers, he had concerns about timelines, recognising that the proposed phasing is going to be very challenging and more costly than a clean break approach. “How easy is it going to be for industry with its new reporting requirements, there is limited time for business to prepare for new reporting requirements in 2023 for EPR to come in in 2024,” commented Mr Bellamy.

Other points he covered included urging local authorities to start collecting plastic films from 2023 and for the idea of litter payments as an “open-ended” cost under the system to be looked at, deeming it inappropriate for businesses to pick up the cost.

He said: “Litter payments are a big area of concern: this is very open-ended in terms of payments. Should business be expected to pay for clearing up the results of an illegal act? Where is consumer responsibility? A report by Eunomia and WRAP on litter but hasn’t been published. Seems entirely inappropriate that business should be asked to do so? Where is consumer responsibility when it comes to litter?”

Q and A

In a busy questions session chaired by Kate Ballard, business development manager at Clarity Environmental, words in favour of competition within the new system rather than just the administrator organising everything came from David Bellamy.

“Let’s not look at the granularity of the sample, let’s aim for a reasonable good point”

Stuart Hayward-Higham, Suez UK

Stuart Hayward-Higham reflected there was a challenge on data, there had been concerns in the past that there was not enough and ideally proportional data was needed, “let’s not look at the granularity of the sample, let’s aim for a reasonable good point.”

On the timeline, Adrian Hawkes was forthright in his view. He said: “I’m beginning to wonder if the timetable is moving from aggressive to impossible the more I think of it. It’s not just the regulations but also all the changes in businesses and within local authorities. We don’t have that clearly mapped out a the moment. I would like to see that as one of the key aspects after the consultation and we can look at the steps in more detail, it is a big issue in my mind.”



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