18 February 2019 by Will Date

Options set out for packaging waste reform

Full details of the options for a reformed producer responsibility system for packaging waste have been published by the government today (18 February).

The details come within one of the four Resources and Waste Strategy consultations (see letsrecycle.com story) which were launched this morning, and run for 12 weeks until mid-May.

Measures have been outlined to overhaul the system of producer responsibility for packaging waste

Central to the proposals around packaging is an aim to ensure that producers pay the full net cost of the recycling and disposal of their products.

This is to address concerns that the current Packaging Recovery Note – PRN – system sees producers only pay between 7-10% of the cost of recycling their products when they become waste, with the burden of cost instead falling largely on councils.

Modelling included in the consultation suggests that producers could be required to pay an additional £629 million per year to comply under a reformed packaging system.

Within the consultation, the government sets out a number of options for the new regime as well as proposals to encourage better design of packaging to support recycling, new packaging recycling targets up to 2030, and steps to improve transparency within the regulations.

Introductory video on the packaging reforms produced by Defra

It is expected that a new system will be introduced from 2023, covering England, Scotland, Wales and Northern Ireland. The government will consult on its preferred option and specific regulatory measures in early 2020.

In its introduction on the proposals, the government states: “We want unnecessary and difficult to recycle packaging to reduce substantially; we want more packaging designed to be recyclable; we want more packaging waste to be recycled; and we want more packaging to be made from recycled material.

Click on image for link to the packaging consultation

“We also want fewer packaging items to be littered and for it to be easier for people and businesses to recycle their packaging waste.”

At the heart of the consultation are a series of alternative models for how the new system will function – which are intended to work in line with other proposals including a deposit return scheme for drinks bottles and cans.

Modulated Fees

These are based around the use of ‘modulated fees’ whereby producers pay more if the products they place on the market are not made from one of a specified set of ‘recyclable’ materials, or a system where producers pay a deposit and are refunded based on the recyclability of their products.

It is hoped that these measures will incentivise packaging producers to make their products more recyclable, discouraging the use of hard-to-recycle black trays, and materials such as PVC and Polystyrene, for example.

The four models are:

Model 1: Enhanced ‘near-to-business as usual’ – compliance schemes
Based on the current compliance scheme model. Schemes levy ‘modulated fees’ on members based on the type and quantity of packaging each handles. The payments a scheme makes to a local authority would cover the cost of collecting and managing packaging waste and meeting any required collection standard.

Model 2: Single not-for-profit producer scheme
Delivery of all aspects of the packaging EPR scheme would be the responsibility of a single organisation. The modulated fee rates would be proposed by the organisation so as to achieve full net cost recovery and would be agreed with government. In this model there is no statutory role for compliance schemes as under the current system.

Model 3: Separate scheme for household/household-like packaging and commercial/industrial packaging
In this model separate arrangements would be put in place for household and household-like packaging waste and for commercial and industrial packaging waste. Arrangements for commercial and industrial packaging would be managed by compliance schemes. The requirements for household packaging would be managed by a single management organisation. This organisation effectively would be the same as that described for Model 2.

Materials such as black plastic are likely to be discouraged through ‘modulated fees’ for producers

Model 4: Deposit-based government managed scheme
For all recyclable packaging producers pay a deposit fee. This would be payable per tonne and would vary by material. For all non-recyclable packaging they would pay a fee, set high enough to create an incentive to use recyclable packaging. Some of the fee would be used to support communications and litter-related measures.

Among the other areas included within the reforms are proposed changes to the point at which producers are deemed responsible for the cost of the recycling of their products.


This could see the introduction of a single point of compliance where 100% of the producer responsibility obligation is placed on one business – the brand owner – for each unit of packaging placed on the market.

This would replace the existing shared responsibility system, whereby the costs are divided between sellers, pack fillers, convertors and material producers.

According to Defra, in moving to a single point of compliance, the obligation “should be on those businesses who have the greatest amount of influence over packaging design and the use of materials.”

Additional responsibilities would be given to online marketplace businesses, to ensure that products sold through these routes are not falling outside of the packaging system.


Proposals for packaging recycling targets up to 2030

The consultation also outlines the proposed approach to targets for the recycling of packaging up to 2030 – starting with interim goals for 2021 and 2022, moving to statutory targets from 2025 through to the end of the decade.

These will incorporate the EU’s Circular Economy package recycling targets, whilst also meeting the government’s own aim to set its own ‘more ambitious’ goals for packaging waste.

Related Links
Packaging waste: changing the UK producer responsibility system for packaging waste


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