The duel over the new EPR scheme for packaging shows no signs of ending as the final base fees are announced. But there is a silver lining for reusables, writes David Burrows.
A wee drama. “We are united in urging the government to reconsider the proposed fees, and to work with businesses to implement a scheme that truly supports the delivery of a circular economy,” said the Scotch Whisky Association (SWA) and friends in a statement late last Friday afternoon (June 27th). “[…] today’s announcement goes against the UK Government’s plans for boosting growth at home.”
Final fees. This, in case you hadn’t guessed, was the drinks, hospitality and pub industry’s response to the final 2025 fees for the extended producer responsibility for packaging (pEPR) scheme. To recap: pEPR transfers the cost of managing household packaging waste from local authorities to the producers that supply that packaging. It was one of a number of new policies announced in 2018 designed to better manage packaging and revamp the related regulations accordingly.
Base fall. Following three previous illustrative publications of estimated fees – which have all attracted the ire of the SWA, the British Beer and Pub Association, the British Glass Manufacturers’ Confederation, WineGB, Wine and Spirit Trade Association, and UKHospitality – PackUK and the government have finally inked the charges per tonne for different packaging materials in the first year of the scheme.
How much? The announcement reads: “Base fees are calculated by dividing packaging waste management costs (for household packaging waste) and other relevant costs by the total amount of household packaging placed on the market. The result is a fee rate which is expressed in £ per tonne of packaging placed on the market.” The materials in-scope are glass (£192); paper and card (£196); steel (£259); aluminium (£266); wood (£280); plastic (£423); and fibre-based composite (£461).
Easy does it. UK regulators said the fees ease the burden of the scheme. Nearly all fees have reduced compared with the illustrative base fees published in December – from 8% less for ‘other’ packaging to 39% less for aluminium. The exception is fibre-based composite fees, which have increased by 1%. PackUK, the scheme’s administrator, said the reductions result from “high levels of industry compliance with reporting obligations and extensive work across the regulators and PackUK to assure and validate the data provided”.
Pay up. The first invoices are due to land in October 2025. Fees for glass packaging have been cut by 20%. WSTA chief executive Miles Beale welcomed the certainty but said the fees remain “hefty”, and “are still significantly more per unit compared with charges across Europe – eight times more than in Germany and three times more than in Croatia or Finland”. Beale also complained that the “promise to exclude hospitality waste, which is disposed of via private waste collections, from EPR has not been delivered either. Unless the Government intervenes, most hospitality waste will be unfairly charged EPR,” he added.
Shop lifter. The British Retail Consortium (BRC) is equally unhappy about all this. The organisation, which represents high street brands and major supermarkets, as well as foodservice companies including Burger King and Costa, Leon and McDonald’s, said it will “continue to emphasise that pEPR remains a significant cost to industry, further exacerbating inflationary pressures”, in an update. Reacting to the jump in inflation recently, BRC director of food and sustainability Andrew Opie said there is “more pressure on costs to come as the £2bn EPR charges on packaging start in the autumn”.
Glass cuts. Defra expects 85% of businesses to raise prices because of EPR, but the WSTA believes that the number of wine and spirit producers forced to put up their prices will be greater still. In a letter to Steve Reed, the secretary of state for Defra, they noted: “Glass is infinitely recyclable but its fees will cover roughly 30% of the scheme’s cost, despite being just 5% of the volume of containers placed on market.”
Double standards. The associations also warned (and have been warning for some time) that producers would have to pay twice for their packaging waste due to ‘double counting’. “[…] businesses which supply to on-trade via a wholesaler are likely to incur fees for packaging that will always end up on business waste streams. This is against the principle of pEPR and needs to be addressed as a matter of urgency,” the letter reads.
Defra responds. A letter accompanying the update, from Defra, DEARA, the Scottish Government and the Welsh Government, noted the concerns around ‘dual packaging’ – that which can be discarded by both consumers and businesses and is currently captured by the household packaging definition. This packaging “can be difficult to track or evidence where it will be discarded when first supplied by a producer”, the officials said, as they promised more sector-specific workshops to try and iron all this out.
More plastic? The fees have also enraged those pushing single-use paper-plastic options. Paul Synnott, co-chair of the Alliance for Fibre-Based Packaging and MD of packaging producer Seda UK, said: “The decision to raise base fees for fibre, whilst lowering fees for plastic will incentivise producers to use more plastic or to import cheaper, less sustainably sourced fibre from overseas.”
Or more reuse? Synnott claimed pEPR will run “contrary to the Labour Government’s commitment to a more circular economy in which plastic waste is reduced”. That isn’t quite the plan – which in fact seems to be (finally) shifting from recycling single-use materials to pushing reusables. Indeed, perhaps the most intriguing element of the above-mentioned letter from officials was the reference to reusable packaging, urging businesses to consider the cost savings from switching out of single-use.
Here are the two paragraphs in full because they are important and will likely be lost amid the noise of industry ire.
“Reuse has huge potential to deliver positive economic, environmental and societal change. Important research published by GoUnPackaged this week, highlights that moving to 30% reuse in grocery retail would lead to a significant reduction in CO2 and material waste, alongside £136m savings per year in pEPR fees, and a £314m – £577m [saving] overall. It offers a commercially viable and environmentally sustainable way forward.
“Efforts to promote reuse are gaining significant momentum and as four nations we are committed to reuse as a core part of the transition to a circular economy. This includes ensuring that pEPR will help drive the transition to reusable packaging – with pEPR fees only being paid once for reusable items regardless of how many times they are reused – alongside other action being taken by each government.”
Rethinking reuse. As Robbie Staniforth from compliance scheme Ecosurety noted: “If you thought the four nations governments were solely focused on packaging base fees, recyclability assessments and fee modulation assessments today…. Think again.”
