A report published by compliance scheme Beyondly, and commissioned by the Alliance for Beverage Cartons and the Environment (ACE UK), found that the true fee could be between £34 and £92 per tonne lower than the current rate.
Based on the tonnages reported by producers last year, this suggests that businesses using FBC packaging may have collectively overpaid between £6.3 million and £13.7 million.
FBC packaging includes materials such as liquid cartons, sandwich wrappers and certain ready meal containers, which combine paper fibres with thin layers of other materials.
The findings have been submitted to PackUK, alongside a call for future fees to be urgently reviewed.
A spokesperson for PackUK commented: “We do not recognise claims that companies are being overcharged by millions due to errors in the way calculations are made.
“The model that is used has been developed with extensive quality assurance, validation and stakeholder engagement, including material specific roundtables.
“We will continue to incorporate new, robust data into the model where relevant, to ensure that it remains up to date and based on best available evidence.”
pEPR collection costs questioned
The report identified that under the current pEPR methodology, PackUK applies a collection cost of £509 per tonne to FBC packaging destined for recycling or disposal.
By comparison, paper and card attracts a collection cost of £264 per tonne.
Charlotte Davies, Senior Consultant for Resource Efficiency and Circularity at Beyondly, explained: “The bulk density assumed for non-liquid cartons is based on corrugated cardboard rather than the lighter retail packaging formats that dominate kerbside FBC waste.
“The market split between liquid and non-liquid cartons also overstates the share of low-density liquid cartons.
“Since recyclate collection costs represent nearly two-thirds of FBC waste-management costs and are apportioned by volume, both factors inflate the volume allocated to FBC waste and therefore the proportion of collection cost it bears.”
Using available evidence on both the liquid versus non-liquid split and revised bulk density estimates, the report found that collection costs attributed to FBCs may have been significantly overstated.
Adjusting these assumptions would bring FBC collection costs much closer to those applied to paper and card and could reduce disposal fees by between £34 and £92 per tonne.
Accounting for flattened cartons
The report also identified that current modelling appears to assume that liquid cartons remain uncompacted throughout the collection process.
In practice, Beyondly noted that consumers frequently flatten cartons before disposal, while collection vehicles themselves exert compressive forces during loading and transport.
If cartons occupy less volume than currently assumed, the associated collection costs could be lower still.
Ben Powell, Head of External Affairs at ACE UK, added: “It is clearly implausible to charge nearly twice as much for local authorities to collect a tonne of FBC than a tonne of paper and card.
“The impact of this discrepancy alone seems to have cost brands millions of pounds more than it should have done last year.
The report also pointed out that misreporting of RBC packaging as paper and card could also be influencing fee calculations.
Powell added: “We look forward to continuing to work constructively with PackUK to ensure disposal fees are fair for all packaging types, which is essential if we want to make our shared sustainability goals a reality.”
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