In March 2022, the UK Government announced that it was delaying the roll-out of the Extended Producer Responsibility (EPR) scheme, which will require producers to bear the full cost of post-consumer packaging disposal, until 2024.
The delay did not surprise many in the industry – it was already apparent that the 2023 timetable was unrealistic, given that the new system has not been finalised. While some argue the delay will hamper innovation by creating uncertainty, our view is that the delay gives much-needed time for producers of consumer goods and packaging to get to grips with what is expected of them and to implement any necessary changes – from establishing new data reporting systems to redesigning packaging.
EPR explained
Extended Producer Responsibility was first introduced in the Government’s 2018 Resources and Waste Strategy for England landmark policy blueprint. The concept shifts the financial burden of recycling or disposing of packaging waste from taxpayers and local authorities onto producers. On the back of the strategy, the Government committed to legislating EPR for packaging, reforming and updating the current producer responsibility system for packaging that has been in place since 1997.
EPR will be phased in from 2024, providing a mechanism for local authorities to recover their household packaging waste disposal costs from the EPR Scheme Administrator, who will recover directly from producers.
Revised timetable: what is required?
From 2024, under the new regulation, companies with a turnover of more than £2m annually who handle or supply at least 50 tonnes of packaging will have to pay a waste management fee. They will also need to buy packaging waste recycling notes (PRNs) or packaging waste export notes (PERNs) to meet their recycling obligations and submit data about packaging and packaged goods they have handled or supplied.
There is also a lower threshold of £1m turnover and 25 tonnes of packaging handled per year; businesses in this bracket are only required to report on the volume of packaging they place on the market each year – not to pay a fee.
Modulated fees based on recyclability will also be introduced from 2025. This idea is to incentivise producers to make more sustainable decisions when designing or purchasing packaging. For example, a producer using easily recycled packaging can expect to pay a lower fee than a producer who uses non-recyclable materials in their packaging.
From 2026, all packaging will need to be labelled under the Recycle Now scheme. There is no minimum threshold, and all products must be labelled with ‘recycle’ or ‘do not recycle’ instructions. A later deadline (31 March 2027) will apply to plastic films and flexible packaging as very few councils currently collect these materials at the kerbside.
For compostable and biodegradable packaging, the Government has confirmed that the ‘do not recycle’ label will need to be applied by 31 March 2026.
Packaging design: a clear brief
Regarding packaging design, brand owners need to switch to materials that can be easily recycled and increase recycled content in packaging.
Combined, these two policies should, over time, transform the UK’s packaging supply chain from a linear economy to a closed-loop system. As well as benefitting the environment through increased recycling rates and reduced use of virgin materials, a circular approach to packaging will have economic and market benefits.
Currently, there isn’t enough rPET available on the market for FMCG manufacturers to honour their commitments to reducing their use of virgin materials. As more plastic is recycled, it will make more raw material available to the reprocessing sector for use either in ‘closed loop’ or ‘open loop’ recycling.
Plastic packaging needs to be “mono-polymer” – constructed from one polymer family to be classed as easy to recycle. Rigid formats such as soft drinks and milk bottles have long been made from mono-polymers such as PET and HDPE – here, the main challenge is ensuring the lid and container are made from the same material – but for flexible films, the situation is much more complex.
Moving away from multi-material laminates
The multilayer laminate films that are highly effective at protecting food and consumer goods from deterioration from light or oxygen for example cannot be recycled, as the process requires the individual component materials within the packaging to be separated. However, in recent years, packaging filmmakers have invested considerable R&D time in developing mono-polymer films that deliver the barrier properties demanded by FMCG manufacturers.
Consequently, Parkside can now offer flexible packaging solutions that utilise mono-polymer laminates based on PET, PP, PR or Paper PE, making them easily recyclable and fully compliant with the forthcoming EPR regulation. These films can be converted into virtually any packaging format – from lidding films to flow wraps, pouches, doy packs and pillow packs – for chilled, ambient and frozen foods, including hot beverages, confectionery, and snacks. As well as non-food products such as pet food, health, beauty and household products and pharmaceutical – to name but a few!
Rather than putting the brakes on packaging design projects, FMCG manufacturers should press ahead with innovation aimed at making packaging easy to recycle. The deadline for EPR compliance might have been pushed back, but it will not disappear. More time isn’t a licence to kick preparations into the long grass – it is an opportunity to come up with packaging designs that are both compliant and clever – and that takes time.
