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www.beveragestandardsassociation.co.uk
Vol.28 | January/February. 2023
Extended Producer
Responsibility (EPR)
The polluter pays is the underlying principle This data provides a clearer a picture of packaging,
globally for producer responsibility schemes although we are concerned that with distributors
including those for packaging. selling to obligated businesses there is the potential
risk of double counting.
We agree, polluters should pay, but how does the
polluter pay,? Which polluters pay? For what is the EPR includes a provision for producers of unmarked
polluter paying? How much do they pay and does this and unfilled packaging to be accountable, in other
depend on the packaging? words pay, for the packaging they sell to non-
obligated businesses. This will require producers to
Principles can be easy to write but transposing them
into executable and understandable legislation can be find out details of their customers’ turnover and
tricky. The principle of the polluter pays is at the heart packaging. Information customers may possibly be
of the proposal for UK wide Extended Producer reluctant to share. Frankly this part of EPR is going to
Responsibility (EPR) and we don’t dispute this, be a pain for distributors dealing with small
although a key polluter, people who drop litter, are customers and will involve them in days of additional
pretty much let off the hook with low fines for littering work.
and little appetite from local authorities to issue fixed EPR also brings us modulated fees for items
penalty notices. This, we believe, is partly because of commonly found in litter. In many senses the
the negative publicity that results when people are packaging industry supports the principle of
fined for breaking the law. packaging that is harder to collect and recycle paying
more than packaging that is easier to collect. This is
The government’s EPR proposals will legally require
obligated businesses to fund the net cost of provided the correct proportion is charged in this
packaging waste management. Obligated businesses way. Under the proposed legislation in England all
fall into two categories. Big businesses turning over packaging categorised as being commonly found in
more than £2 million a year and placing more than 50 litter bins pays an additional fee whether it ends up in
tonnes of packaging on to the market - known as litter bins or not.
POM - who will report and pay fees. Small businesses This makes a further provision of EPR very important
turning over £1-£2 million annual turnover and 25 - for the foodservice sector - mandatory paper cup
49 tonnes POM annually will report their packaging take back. This requires businesses employing more
only. Note this is net cost which takes into account the than 10 full time employees selling drinks in paper
money earned by say councils from the materials sent cups to take back used cups whether their own or
for reprocessing. those of their competitors. We pushed for mandatory
As of 1 January this year, did you know if you fall into cup take-back to be included as it removes from EPR
one of the above categories you should be collecting fees those cups that are collected and can be proven
packaging data even though the statutory instrument to be recycled.
covering this requirement won’t be introduced until
the end of March?
