OPINION: Delays to the UK’s EPR implementation – a blessing in disguise

Martyn Tickner, chief advisor at the Alliance to End Plastic Waste, discusses the delays to the UK’s EPR scheme and why it might not be such a bad thing.

OPINION: It has been a long and winding road for the UK’s Extended Producer Responsibility (EPR) scheme. Initially proposed in 2018 as part of the Resources and Waste Strategy, last year’s inflationary pressures triggered the latest plot twist, with the scheme’s rollout being pushed back a year from 2024 to 2025.

Martyn Tickner

Rather than a negative, this move represents a key opportunity granting the government additional time to finesse the scheme’s design with industry players. Regulators can now ensure thorough alignment across the entire value chain while enhancing waste management capacity, paving the way for a successful EPR scheme.

The Plastic Waste Management Framework, published by the Alliance to End Plastic Waste with the support of Roland Berger, identified EPR as one of the most effective policy instruments for increasing recycling rates. Under EPR, the responsibility for achieving certain recycling rates lies with packaging generators, and in particular, consumer goods producers. Previously when EPR systems were implemented, recycling rates for packaging and items like Waste Electrical and Electronic Equipment (WEEE), tyres, and batteries increased by up to 15 to 25 percent over a period of 10 to 15 years.

Broadening local and international stakeholder engagement

EPR is a significant step towards advancing plastic circularity in the UK, by ensuring that funds generated through the scheme are reinvested into plastic recycling infrastructure. However, in many countries, the maintenance of EPR systems across the value chain often faces resourcing constraints. As such, a well-designed EPR scheme should establish transparent processes along the value chain, ensuring that collected fees are ringfenced and funnelled back solely into resource management.

On top of that, a robust EPR system requires a unified strategy that encompasses the entire plastic value chain. Particularly, legislators have a key role to play in ensuring the successful implementation of the EPR systems.

The one-year delay allows the government and its recently appointed EPR Scheme Interim Steering Group to establish clarity in all terms used in the EPR legislation for smoother implementation of regulations, and to determine the precise calculation of EPR fees and EPR performance reporting. The scope of the various resource streams, the consequences of non-compliance, as well as reporting and monitoring procedures should also be clear, detailed, and exhaustive to eliminate complications.

The government is best placed to take the lead in conducting consultations with industry stakeholders such as brand owners, waste collectors, recyclers, and municipalities to gather input on the design of the scheme, and to set clear and realistic objectives that will pass industry muster.

Furthermore, the one-year delay will allow the government to align itself with global best practices and potential mandates. With the Global Plastic Treaty negotiations set to wrap up this year, the government can incorporate insights and lessons learned from international negotiations, ensuring that its EPR scheme is not only robust but also adaptable to evolving global standards.

It is crucial to understand that EPR is not a one-size-fits-all solution. For an EPR system to be efficient, financially sustainable, and technically feasible, it needs to be co-designed and led by the industry, with the government providing reliable oversight to enhance transparency and accountability.

Creating synergy with waste management technologies

EPR fees collected from packaging producers can be used to bolster the funds available to local authorities in their efforts to enhance collection, sorting and recycling of household waste. Nevertheless, a successful EPR system still hinges on effective efforts by households in contributing to their own waste management.

In a survey of consumers conducted in the UK last year, over half of the respondents expressed confusion over their role in the household sorting of waste necessary for recycling. 42 percent said they would take a guess when unsure about the recyclability of packaging, which means contaminants are accidentally being placed in recycling streams.  A further 20 percent said they opted not to recycle. This underscores the necessity for the public and private sectors to improve education, research and investment to enhance household waste collection and sorting.

Continued advancements in identification and sorting technologies, such as optical and mechanical sorting, as well as AI object recognition, can also expedite the sorting of waste after it is collected at a household level. One such example is the innovative digital watermarks on packaging which can be detected by cameras and inform the sorting process, leading to higher-quality recycling.

Although the government’s delay in collecting EPR payments will push back the access of municipalities to much-needed funds, this period can still be leveraged to actively engage industry stakeholders, establish streamlined processes, and enhance the overall funding mechanism. This approach will help foster improved innovation and create a more seamless implementation process when the EPR scheme is eventually rolled out.


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