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Extended Producer Responsibility

30 Oct 23

Zero Waste Scotland is currently supporting the Scottish Government in its work with the UK government to review our extended producer responsibility schemes.

What is Extended Producer Responsibility (EPR)?

The concept of extended producer responsibility (EPR) is about ensuring that producers bear responsibility for the environmental impacts of products they place on the market, and are incentivised to reduce these impacts. At the heart of this lies the opportunity to consider the whole lifecycle of a product. EPR has the potential to influence design, maximising a products useful life through reuse, repair and durability, as well as ensuring that products can be recycled back into high quality products when they reach the end of their lives. 

This can be through a variety of mechanisms. As a minimum, EPR can be used to ensure that producers pay the costs of correct management for their products when they become waste. This is particularly important for hazardous products and materials such as batteries and electrical equipment. However, EPR can also drive better design choices for a wide range of products by ensuring environmental impacts are reflected in the costs producers must pay. 

Illustration showing the extent of a extended producer responsibility scheme

Why do we need it? 

At present, approximately 80% of Scotland’s carbon footprint is caused by the goods and services we consume. This includes extraction, transport and manufacturing processes. In the current 'linear' system, products are made, used, and disposed of. This is not good for businesses, people, or the environment. 

Making better use of materials would substantially lower carbon emissions and protect habitats and biodiversity vulnerable to the extraction process. 

EPR is a powerful measure that can accelerate progress towards a more circular economy, where products are designed to be reused, repaired and remanufactured, rather than disposed of. They can also ensure that products are disassembled and recycled into new high quality products. This will help Scotland to meet Sustainable Development Goal 12, which requires countries to ensure sustainable consumption and production patterns.

This will help Scotland meet the circular economy ambitions set out in Making Things Last (2016), and the forthcoming CE Bill and Route Map which aim to meet current waste reduction and recycling targets and drive the transition towards broader environmental targets post-2025.

Keeping products in use for longer reduces the environmental, social and economic impacts of extraction, manufacturing, use and disposal, helping to reduce global impacts on biodiversity, emissions reduction targets and contributing to a just transition for all. The job and skills opportunities contribute towards a fairer, greener wellbeing economy.

What can an EPR scheme do?

EPR schemes can place responsibility for the environmental or financial impacts of a product on the producer. Currently, they are mainly used to ensure there are responsible disposal options for products at the end of their useful lives. Producers may take responsibility for doing this themselves or pay another organisation to do it, such as a local authority or private waste management company.

The potential uses of EPR are much wider than this, as it is increasingly recognised as a powerful tool to address the wider environmental impacts caused by choice of materials in a product or the way it is designed, accelerating towards a circular economy and contributing towards our response to the climate emergency and other environmental impacts. 

EPR can act as a tool to improve product design in order to prolong the lifecycle of materials, to increase reuse and therefore keep materials in use for longer, or enhance recycling at end of life to offset the need for virgin material. It can also disincentivise unnecessary disposable items that are frequently discarded after one use. This reduces pollution and waste. 

How do typical EPR schemes work?

EPR schemes can be mandatory (introduced by a government via legislation) or voluntary. They place obligations on companies who make goods available to the market – the producers. Schemes may allow producers to choose whether they meet obligations themselves or pay another organisation to do this on their behalf. Some schemes require producers to register with a Producer Responsibility Organisation or compliance scheme to ensure they meet their obligations.

Producers may be required to pay fees as an upfront charge based on the impact of a product, provide physical collection of their products at the end of their lives, or through market-driven mechanisms such as Packaging Waste Recovery Notes to increase investing in waste management infrastructure and ensure reprocessing of material takes place.

Where are we just now with EPR?

Making Things Last – a circular economy strategy for Scotland’, published in 2016, set out an ambition to take a more comprehensive approach to EPR, to encourage reuse, repair and remanufacture and address the costs of recycling and disposal.

In early 2019, the Scottish Government and the other UK administrations undertook joint consultations on reforming the UK packaging producer responsibility system. Following strong support from respondents for the principles and outcomes, the governments committed to progressing the policy proposals and to introducing a new EPR scheme for packaging.

This was followed by a second joint consultation in 2021 to discuss specific policy proposals for the introduction of EPR for packaging. The government response set out the policy intentions across all the components of packaging EPR and, in particular, intentions of the scheme to change the data that producers are required to provide in 2023-24 to support implementation.

In 2023 the UK government announced deferral of the packaging fees for 1 year (to 2025) accompanied by a relaxation of the data reporting requirements for 2023. The 4 nations also released a consultation on the draft Regulations which will introduce the measures set out in the Government Response to the second consultation.

Revised Extended Producer Responsibility schemes

The Scottish Government, the UK and Welsh Governments and the Department of Agriculture, Environment and Rural Affairs in Northern Ireland (DAERA), are consulting on reforms to the current producer responsibility system for waste electrical and electronic equipment (WEEE) which will introduce extended producer responsibility (EPR) from 2026.

The consultation proposals, along with those in the accompanying Call for Evidence, aim to encourage greater reuse and recycling by making it easier for the public to deal with their WEEE responsibly. It proposes to expand producer responsibilities to online marketplaces and distributors, and to create a new category specifically for vapes. Give your feedback here.

Existing Schemes

Scotland is part of four UK EPR systems covering:  

  • Packaging – Zero Waste Scotland is supporting Scottish Government, along with the other UK administrations, to design a packaging EPR scheme that has a positive long-term impact, is consistent and works well for all citizens. We are working to ensure that the scheme is appropriately designed to help meet Scotland's objectives.
  • Waste Electrical and Electronic Equipment (WEEE) – Zero Waste Scotland is supporting Scottish Government, along with the other UK administrations, to review the current WEEE EPR scheme to improve collection, increase recycling increase reuse and keep products in use for longer ensure that the scheme is appropriately designed to help meet Scotland's objectives.
  • Batteries – Zero Waste Scotland is supporting Scottish Government, along with the other UK administrations, to review the current UK batteries EPR scheme to increase recycling rates, adopt circular economy principles to reduce consumption of critical raw materials and rare earth elements and consider ambitious proposals for a rapidly changing product group.
  • End of Life Vehicles.

Zero Waste Scotland continues to work with organisations to further policy discussions on producer responsibility. To that end, we have explored mattress EPR with the National Bed Federation, commissioned research to explore options to improve the circularity of waste tyres and were part of initial discussions on fishing gear EPR to align with Single Use Plastics Directive requirements pre-EU Exit. 

What is the future of EPR?

The possibilities for EPR are huge and could cover everything from food packaging to building design. However, EPR schemes have typically been used to maximise recyclability and meet recycling targets for a limited number of products. There is a huge potential to combine EPR with other policy measures as part of a Product Stewardship approach that fully considers the value chain, all actors within it and designs policy tools to minimise whole life cycle social, economic and environmental impacts of products.

Zero Waste Scotland is supporting the Scottish Government, who are committed to working with the UK Government and the Devolved Administrations of Wales and Northern Ireland to improve and expand the use of EPR to accelerate a circular economy. Zero Waste Scotland recognises the huge potential of EPR to tackle a range of environmental issues associated with the production, use and disposal of products and materials.

Our recent report Reducing Resource Extraction and Use: Producer Responsibility for the Circular Economy proposes an innovative policy solution to address the impacts of products on climate change, pollution, biodiversity and social inequity – all of which are driven by overconsumption. This report builds on traditional extended producer responsibility (EPR) policy, which focuses on end-of-life waste management, to better incentivise producers to minimise material use and move towards a circular economy.

With the impacts of the climate emergency already being felt, this is more important than ever. It is important to note that EPR is one of a range of policy tools and interventions that can address the environmental impacts of the products we use. Policies must be designed carefully to optimise their impact and avoid unintended consequences.