Defra plans producer responsibility organization appointment to propel packaging EPR

The UK Government is considering the appointment of a Producer Responsibility Organisation (PRO) as part of its packaging EPR (pEPR). The move comes in response to concerns voiced by the food packaging industry regarding the scheme’s efficiency and responsibilities. 

We discuss the pEPR update with the UK’s Department for Environment Food and Rural Affairs (Defra) and the Food & Drink Federation (FDF), which represents the interests of F&B manufacturers in the country.

“On 30 April, the UK Government notified an amending Statutory Instrument (SI) to the pEPR Regulations to the EU in respect of Northern Ireland. To build on these reforms, the amending SI will introduce a number of changes from year two onward,” a Defra spokesperson tells Packaging Insights. 

The spokesperson highlights the following changes as significant: 

• Enabling the appointment of a PRO, supporting greater producer leadership and enabling the delivery of an efficient and effective scheme 

• Extending offsetting provisions to closed-loop recycling of food-grade plastic 

• Operability changes. 

A spokesperson for the FDF tells us: “We are delighted that the four nations are legislating to appoint a PRO, which gives industry the green light to drive forward an EPR scheme that will work collaboratively across the value chain to create the innovative and effective recycling system the UK needs.”

“We’re also pleased to see that the government has listened to industry’s concerns and changed the law, so that it no longer unfairly penalises innovative manufacturers that use their own closed-loop recycling systems.”

Efficiency and dual-use

Defra informs us that alongside notification of the amending SI, it has “set out both our commitment to explore further changes to pEPR and broader measures, in response to feedback from stakeholders.”

Following industry feedback, Defra will support local authorities to improve pEPR outcomes and value for money.These feedback-based changes include: 

• Efficiency and effectiveness of Local Authority costs: a commitment to consider further measures to ensure that investment through pEPR supports local authorities to deliver improved outcomes and value for money

• Dual-use: to work with businesses at pace to explore proposals put forward regarding the treatment of dual-use packaging, which includes packaging that can be disposed of by businesses and households. It also seeks to identify workable solutions that may require consultation on further regulatory amendments.

The FDF says it has “convened more than two dozen leading businesses from across sectors to develop a PRO which enables a circular economy for packaging recycling.”

“Our vision is for a collaborative, representative not-for-profit organization that supports industry to cut its use of packaging, supports councils and waste managers to improve recycling performance, and ensures value for money for producers’ billions of pounds of fees.”

The spokesperson asserts that the federation expects to see a PRO that “meets the expectations of producers, while working in collaboration with the full packaging value chain to help identify any barriers to its success and ensuring that all stakeholders, whether that’s local authorities, compliance schemes, or producers of packaging, have bought into the aims of the organization.”

Calls for infrastructure updates

The FDF says that while many of the government’s changes are “huge leaps forward in the right direction” for the pEPR, there is still “significant work” to be done to make the policy viable ahead of its fast-approaching start date. 

“This includes the fact that the government’s current definition of ‘household waste’ simply doesn’t work. With the current phrasing, food and drink that is consumed at bars, restaurants, and even by hospital patients, will still be classed as ‘household waste’. This is unfair,” the spokesperson explains.

FDF says F&B consumed at bars and restaurants should not be considered “household waste” under the UK’s pEPR.“We continue to engage with Defra to find a pragmatic solution whereby producers pay a fair and transparent EPR fee for products that really end up in household waste bins. This could include self-certification, with producers providing a suitable level of evidence that their products are not ending up in household bins, be that through supply to the NHS, public institutions, or hospitality venues.”

The FDF adds that the UK’s recycling rates have flatlined in recent decades, arguing that pEPR alone will not turn that around. “To improve recycling rates, the government needs to ensure producers’ billions of pounds of fees are well-spent. This includes developing a plan to upgrade our recycling infrastructure, so it becomes possible for us to recycle food-grade packaging back into packaging.”

“However, the government should go further as soon as possible by ensuring producer fees are ring-fenced at local authority level, so money invested in recycling is spent on recycling.”

The UK’s upcoming pEPR scheme aims to shift the responsibility and cost of packaging waste management from taxpayers and local authorities to packaging businesses. The first EPR payments are expected at the end of this year.

At Packaging Innovations 2025, Margaret Bates, the head of the UK pEPR scheme administrator, told Packaging Insights that pEPR could transform the packaging value chain and incentivize environmentally sustainable packaging design.

Meanwhile, the Digital Watermarks Initiative HolyGrail 2.0 for packaging waste management called for support from the pEPR PRO in order to expand its scope.