Marc Jourdan, IEMA Policy & Engagement Lead provides an overview of the IEMA recommendations to the UK Government on Extended Producer Responsibility for packaging.

In December 2018, the Government released the Resources & Waste Strategy, announcing its plan to address resource efficiency and the “market failure” of waste production. As part of the strategy, Government set out its plans to reform the UK Packaging Producer Responsibility system, subject to consultation with the public. Responding to the first consultation in 2019, IEMA welcomed the proposal to Extend Producer Responsibility, cautioning that the scheme’s success in helping to maximise resource utilisation and resource effectiveness would depend on it being well designed in accordance with key principles such as packaging design and governance arrangements.

Two years on, the government has now put forward a second more detailed consultation setting out proposals for how it will integrate these principles into the new scheme. IEMA has now submitted its recommendations to Government. Some of the key recommendations focusing on the different chapters of the consultation are set out below:

  • On packaging targets: We feel that the proposed minimum recycling targets are not ambitious enough. We are concerned that low and static targets, and a lack of parity between material targets, would create a lack of clarity and comparability, and act as a disincentive to action. We call for the targets to be higher than the bare minimum required to help drive us towards the net zero and current circular economy targets set by the UK government and the Devolved Administrations. For this reason, we believe that the targets for these materials should be set at 62% for plastic, 50% for wood and 69% for aluminium.
  • On producer obligations for full net cost payments and reporting: We recommend that online marketplaces should be obligated under EPR for unfilled packaging in addition to filled packaging, to show parity with physical distributor retailing.
  • On labelling: We support the use of approved labels, whereby Government would specify in regulations the criteria that labels must meet. 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.
  • On payments for managing packaging waste: Local government plays an integral role in the delivery of waste and recycling services across the UK. They are therefore a key stakeholder that will assist us in achieving these material recycling targets. We feel that local authorities should therefore be rewarded for making significant beneficial changes to packaging waste systems and/or where they demonstrate that measures have achieved very low levels of waste.
  • On payment mechanisms for packaging waste collected from businesses: We believe that a compliance scheme led, producer funded, business packaging waste management cost rebate system is the most suited payment mechanism to embed the polluter pays principle and ensure waste producers meet full net cost obligations and therefore it should be implemented.
  • On reprocessors and exporters: The biggest challenge in terms of reporting on the quality of packaging waste received at the point of reprocessing and/or export would be conducting quality control inspections. Future legislation should aim to introduce clear standards and definitions to help level the playing field and provide consistency in reporting.
  • On implementation of EPR: We recommend a phased approach to implementing EPR starting in 2023 as opposed to later implementation as time is of the essence. We need to take further action to tackle the issue of packaging waste.

Overall IEMA welcomes the proposals and is supportive of a long-term strategy that builds infrastructure for all materials. We believe the proposals should allow flexibility to incorporate future changes to our use of materials, and to ensure there is consistency in application of these proposals, without contradicting those set out under other policy mechanisms including deposit return scheme and the plastic packaging tax. We also note these proposals will require swift action by DEFRA over the coming months to ensure alignment with and attainment of the Environment Bill targets.

IEMA’s response was informed by engagement with members and expert stakeholders, including a member workshop, co-facilitated by the IEMA Circular Economy Network steering group.

With the consultation process now closed, we expect government to review responses received in conjunction with other consultations that are running in parallel under the Resources & Waste Strategy including:

- Introducing a Deposit Return Scheme in England, Wales and Northern Ireland (closed)

- The Waste Prevention Programme for England: Towards a Resource-Efficient Economy (closes 10 June): The consultation is asking respondents to provide their views on what they think regulatory and industrial priorities should be for managing resources and waste for textiles; construction; furniture; e-goods; road vehicles; packaging; single-use items and plastics; and food.

- Consistency in Household and Business Recycling in England (closes 4 July): the Environment Bill requires all businesses producing household-like waste to arrange for the separate collection of 5 recyclable waste streams: glass; metal; plastic; paper & card; food waste. This consultation seeks views on the materials to be included in each of these waste streams, timelines for when the requirements will be introduced and possible exemptions.

We encourage members to submit responses on behalf of their own organisation before the deadlines.

IEMA will stay close to developments and update members as appropriate once government publishes its response.

To access the IEMA EPR Consultation Response then please click here.


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