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Packaging EPR FAQs

Extended Producer Responsibility is a way of ensuring that producers are financially or operationally responsible for the environmental impacts of their products. Find out more about Extended Producer Responsibility here.

What is Packaging Extended Producer Responsibility?

Packaging Extended Producer Responsibility (Packaging EPR) places obligations on producers who place packaging on the market to ensure material is managed properly at end-of life. This may require changes to the design of packaging, inclusion of consumer labels, financial costs of collection and sorting infrastructure, monitoring and evaluation of material in the supply chain, communication activities and more. 

The current UK scheme requires obligated producers to purchase of Packaging Waste Recovery Notes (PRN’s) or Packaging Export Recovery Notes (PERN’s), sold by organisations that reprocess packaging, which provide evidence that a proportion of packaging similar to the types used in their products, has been recycled. The price of PRN’s varies subject to market conditions but has typically resulted in producers paying a small proportion of the costs associated with managing packaging at the end of its life. 

The revised packaging scheme will require producers to pay the full net cost of treating packaging that they place on the market and has the potential to incentivise other changes such as better packaging design and preventing waste at source. Changes to who is responsible for compliance, labelling requirements, scheme governance, export requirements, and reporting and data requirements are also proposed. 

FAQs

Here are answers to frequently asked questions about Packaging Extended Producer Responsibility.

What is Zero Waste Scotland’s role?

Zero Waste Scotland provides technical support to the Scottish Government on parts of the scheme design. These include:

  • What is included within the costs that producers must pay for (known as full net cost recovery);
  • How the scheme should be governed, including what sort of organisation should do this and what information producers must provide;
  • How local authorities should be paid for the collection and sorting of material;
  • How packaging should be labelled to ensure that consumers can tell whether it is recyclable;
  • What targets should be set for recycling rates;
  • Carrying out research where there are gaps in the information needed to design the scheme. 

The review of the packaging EPR scheme is being led by Defra, but is a joint initiative involving the Devolved Administrations of Scotland, Northern Ireland and Wales. The governments of all the nations are working together to ensure that the revised packaging EPR scheme aligns with existing policies as far as possible, and allows some variation based on local needs and priorities. 

Which other countries operate a packaging EPR?

Packaging EPR is one of the most common forms of EPR around the world. The majority of EU member states have schemes, in order to comply with EU Directive 94/62/EC, but there are also schemes in other countries and regions around the world. Packaging EPR globally takes a wide variety of forms, but typically producers are responsible for collecting, sorting and either recycling or disposing of the waste from households and commercial and industrial sources. Producers can fulfil these obligations directly, or by paying a third party to facilitate the obligations on their behalf. 

Revisions to the Waste Framework Directive (2008), introduced new requirements for EPR schemes, requiring producers to cover the entire cost of waste management for the products they place on the market. This includes costs relating to collection, sorting and treatment of the waste, as well as funding information campaigns and data gathering and reporting. 

Why is the current system being reviewed?

The current packaging EPR scheme uses Packaging Waste Recovery Notes (PRNs) whereby producers buy sufficient PRNs in order to offset their obligations using the ‘producer pays’ principle. It is estimated that this amounts to around 10%, on average, of the total costs of managing packaging waste at end-of-life. 

Producers do not currently pay the full costs associated with the material that they place on the market. This means that Local Authorities and society as a whole must bear the majority of the financial cost of dealing with packaging materials at the end of their useful life. In addition, although the money raised by PRNs is intended to improve packaging waste management it is often unclear whether this is the case. 

As the price of PRNs is not linked to the recyclability or environmental impacts of the materials, the current system does not incentivise improvements in packaging design or penalise the use of materials that are difficult to recycle. This means that materials are often reprocessed into much lower value goods or lost to landfill or incineration after just one use. 

There is also a lack of transparency about the actual fate of materials, especially when they are exported for reprocessing in other countries. This means it is difficult to tell if materials are being handled responsibly. 

A redesigned packaging EPR scheme will help to reduce these issues, as well as driving a shift towards a more circular economy, ensuring that materials are used for longer, and reprocessed to higher value use. 

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