The purpose of Extended Producer Responsibility (EPR) for packaging as a policy mechanism is to increase the incentive for producers to make better, more sustainable decisions at the design stage, and make it easier for packaging to be re-used or recycled at end of life. It does this by placing the financial cost of managing packaging at end of life on producers, with harder-to-recycle materials increasing their costs.
To help mitigate this unprecedented financial burden you should act now to improve the impact of your packaging. Here are the top five actions you should be considering.
Increasing your data coverage and accuracy should be a continual focus and is often a key challenge for producers. Data submission that are ‘as accurate as reasonably possible’ are a legal requirement under packaging EPR legislation, but this same data is essential for making informed strategic decisions too. It can quickly reveal where you should be focusing efforts to most efficiently reduce your environmental impacts and EPR cost liabilities.
For example, there may be a small percentage of products, suppliers or packaging formats that make up the largest proportion of your EPR liabilities. Prioritising these will reduce the impact of your packaging and EPR costs the fastest.
You can get started right away with our articles explaining how to improve your data. Ecosurety members can also explore their packaging compliance obligations and cost trends with My packaging compliance summary analytics. Members on our Advanced or Premium packages can model future EPR scenarios with My packaging EPR cost modelling analytics.
PRN obligations and EPR fees are based on the weight of your packaging, therefore a key incentive of EPR is to reduce the amount of packaging you are placing on the market in the first place. First, check if you can remove unnecessary packaging. For example, do all packaging components serve a critical function? Does the product need packaging at all?
Of course, you may not be able to remove packaging without compromising the protection of the product. In this case, check if you can reduce the amount of material used. By lightweighting packaging and removing even grammes of material from products that you sell thousands of, you can quickly gain environmental and financial savings.
Don’t forget the risk of going too far however – inadequate packaging that leads to damaged products can have a significant carbon and financial impact.
For packaging you cannot reduce further, check if you can switch to more easily recycled materials. Modulated EPR fees will be higher for materials that are deemed difficult to recycle, whilst those that are readily reprocessed will attract the lowest costs.
Recyclability is not only impacted by material type. Can you switch from multi-material packaging that is difficult to separate, to easily reprocessed mono-material packaging? If you must use multi-material, can you ensure it is easily separated by the consumer for recycling? This aspect is expected to form part of the recyclability assessment that will inform future EPR fee modulation and is one you should be considering now.
Whilst fee modulation and material guidance have not been shared by Defra yet, they have announced the difficult-to-recycle materials that are under consideration for higher modulated fees. Find out more in our guide to modulated fees.
EPR incentivises producers to take-back and recycle or refill used packaging materials from consumers that are not commonly recycled at kerbside, by enabling you to offset it against your EPR waste management fees.
To benefit you must meet specific requirements:
You must have reported placing the same household packaging material on the market in same period
The material collected must not appear in the list of commonly collected packaging materials published this gov.uk page
You must be able to evidence that it has been recycled, including the nation it was collected and recycled in
The material collected can include packaging belonging to other brands
Reusable packaging can also count as self-managed consumer household packaging waste, if you have recovered it from customers and it has been re-used and refilled at least once but is no longer being used as packaging. For example, a laundry detergent bottle in a refill scheme that has been returned by the customer for refilling. Again it needs to not appear on the list of commonly collected packaging materials to be offset against fees.
If you are already operating a take-back scheme to recycle or refill packaging, check if you meet the criteria to offset it against your EPR fees.
If you are not already operating one, it is certainly worth investigating if you can for any packaging that uses materials not commonly collected at kerbside.
Switching from single-use to reusable or refillable packaging will reduce your EPR liabilities, since you only report it the first time it is placed on the market. You may even be able to offset it against EPR fees, as stated above. Defra have stated they plan to introduce a packaging refill target as well, to help drive an increase in adoption.
If you’re not sure where to start, you can get up to speed now with these essential resources by sustainable packaging consultancy Root, created for Ecosurety members:
Don’t stop at reusable consumer packaging however - reusable transport packaging is already widely used in the form of pallets, cages and trays, but are you benefiting from it as much as you could be? This article explains why reusable packaging for supply chains is business critical today.
All the improvements above start and end with data, which enables you to understand what to improve and measure the impact of any improvements. We highly recommend you explore the insights available in My packaging compliance summary analytics and My packaging EPR costs modelling analytics. If you would like to talk to us about how to benefit more from your packaging data, please contact your account manager.
Once you are ready to drive improvements to your packaging, we highly recommend speaking to our valued partner Root, who can help identify the best way to get your product to the customer using fewer resources and with a proven lower impact.
Marketing Project Specialist
Ben helps drive marketing communications and projects for Ecosurety, including project managing the launch of the Ecosurety Exploration Fund and website content development.