Spring has brought two new consultations on EPR and DRS. There are 495 pages. Have you read them yet?
Two new packaging consultations finally landed on Wednesday: one on extended producer responsibility (EPR) and the other on deposit return schemes (DRS). These will “boost recycling, tackle plastic pollution and reduce litter”, the government said. There is a lot to unpick.
In all, there are 213 pages on EPR and 103 on DRS. There are also impact assessments for each, extending to 93 and 86 pages respectively. As Alan Partridge would say: don’t drop them on your foot.
They’re not just lengthy but labyrinthine. The impact assessments “are more complex than the Theory of Relativity [but] should also be read to try to comprehend the scale of likely cost”, noted Phil Conran from 360 Environmental, a consultancy.
Total costs for packaging producers will be “in the region of £2.7bn” in the first full year for EPR (which, as some have already noted, is a fair bit higher than previous estimates). Split thus: £1bn for packaging waste collected from households; £1.5bn for packaging waste collected from businesses; and £200m for the management of bin and ground packaging litter. This is not a new cost, the government said, but a “transfer from one part [of the economy] to another”.
Indeed, under EPR, which is being developed on a UK-wide basis, manufacturers will pay the full costs of managing and recycling their packaging waste. Harder to recycle or reuse means higher fees. This includes
biodegradable and compostable plastics, which are likely to attract higher rates “until such time as the state of evidence, collections and infrastructure for this packaging can be improved”. (It wouldn’t hurt if the government published the findings from its call for evidence on biodegradable, compostable and bio-based standards that closed 18 months ago).
Stuck on labels
Compostables will also be labelled ‘do not recycle’ under a proposed new mandatory labelling scheme. A binary system has long been preferred – ‘recycle’ and ‘do not recycle’ – given that it provides the public with consistency and clarity (nine in 10 respondents to the first EPR consultation thought it was a good idea). And yet the government appears to have merrily confused things.
The consultation throws up two options. One is a single labelling scheme with all packaging using the same labels.
The other is to use “approved labels”. The government would check these to “ensure consistency of [the] message to consumers” but allow “some flexibility” in how packaging is labelled. “Producers could either choose to establish their own label or they could choose to subscribe to a labelling scheme and use the labels and services provided by that scheme,” the document explains.
A variant of this (are you still with us?) could be to set the ‘not recyclable’ label in stone and only offer flexibility in the label for packaging that is ‘recyclable’. You can guess which option the government likes best.
Supermarkets and manufacturers should be able to stick with the on pack recycling label (OPRL), which may well speed the process. Though mandatory labelling by 2026/27 hardly seems ambitious (especially given how annoyed and confused the public is with the current approach).
As Margaret Bates, executive director at OPRL explains: one of the reasons that people want recycling labels is clear and consistent messaging “so I look forward to hearing how enabling producers to develop their own labels and the potential for multiple recycling labels will be received”.
OPRL, which has already moved to a binary approach, has widespread coverage across grocery and manufacturing (93 of The Grocer’s top 100 brands are signed up, for example). Three in four shoppers also recognise it. Some of the big foodservice brands are also members (McDonald’s, Costa, Starbucks and Caffè Nero among them) but there are apparently significant gaps (The Package has tasked OPRL with producing data to quantify its foodservice coverage).
Dodgy labelling, let’s not forget, is what got Hugh Fearnley-Whittingstall’s cup campaign off the ground in 2016. Industry has tried to improve recycling of ‘recyclable’ cups through various schemes but has the government lost patience? It is proposing a mandatory “takeback scheme”, which could boost recycling rates to 39% from the current 0.25%, the government said.
That higher figure is based on the ‘Leeds by example’ work run by Hubbub, and involving the likes of Starbucks, Ecosurety, Costa, Bunzl and a number of others. There is also a nod in the document to the members of the national cup recycling scheme (Costa, McDonald’s, Pret A Manger, Caffè Nero, Greggs, Burger King, Pure and Lavazza Professional). But these are responsible for only 36% of the disposable cups sold, which shows voluntary approaches only get you so far.
The consultation reads: “Mandatory takeback would require businesses selling filled disposable paper cups to provide for the separate collection of used cups (either generated in-store or consumed ‘on-the-go’), through both in-store and front of shop collection points, and to arrange for the collection and recycling of these cups. The takeback requirement would extend to accepting all disposable paper cups at these collection points irrespective of brand or where the drink was purchased.” There will also be reporting requirements and targets within the government’s new scheme (which actually aligns with the EU’s single-use plastics directive objectives to reduce consumption of cups).
The Foodservice Package Association appears delighted with the news. The national scheme and work by Hubbub certainly provides a foundation for what could be achieved to lift stubbornly low recycling rates for cups. But isn’t reduction the name of the game here? If consumers can happily recycle their single-use cups they might not bother with reusable ones.
Indeed, a mandatory takeback scheme (cunningly) allows the government (and industry) to boot any thoughts of a so-called ‘latte levy’ into the long grass. Scotland is still actively pursuing a cup charge, while in the south the powers for charges – which have been shown to effectively nudge people towards reusables – will be ready and waiting in the delayed environment bill. Is the government willing to use them?
The government reckons it is still on track to meet its target to have EPR in place by 2023 (the cup scheme is planned for then too).
DRS, however, has slipped to “late 2024 at the earliest” in England, Wales and Northern Ireland – a decision that has irked green campaigners. Scotland is currently considering a second delay to its DRS but still hopes to start ahead of the rest of the UK (whether it is doing this to deliberately annoy everyone else or spur them to get on with their own schemes is moot).
The UK government is proposing a DRS capturing PET plastic bottles, glass bottles, and steel and aluminium cans. This is in line with Scotland’s scheme. Campaigners want all materials in there, though, so milk bottles (HDPE) and cartons (fibre and foil) too.
Expect some sparring on sizes too. The DRS consultation invites feedback on whether the DRS should be an “all-in scheme” (including drinks containers up to 3l in size) or an “on-the-go” one (drinks containers under 750ml in size and excluding those containers sold in multipacks).
Green Alliance, a think tank, has warned it would be “a mistake to arbitrarily leave out some materials or cut off containers above a certain volume”. An all-in scheme would offer “the greatest potential for scaling up to promote reusable containers in the future”, it noted in evidence submitted to the live DRS inquiry being run by the environmental audit committee.
The Foodservice Packaging Association begs to differ. “Quite simply DRS should be based solely on-the-go,” it noted in its submission. “As on-the-go collection and recycling rates are significantly lower than kerbside, this is where the biggest leap in recycling rates is to be gained with the added potential to reduce litter.”
All interested parties now have 10-and-a-half weeks to prepare responses to the consultations. And for those not content with only 495 pages to sift through, a third consultation will arrive shortly on the introduction of consistent recycling collections for all households and businesses in England. The sooner the better really, given that this overlaps intricately with both DRS and EPR.