Today’s publication of the report by the House of Common’s Environmental Audit Committee on coffee cups reflects a wider public interest in sustainable production and consumption. Such interest has driven a policy debate that is focussed on very specific issues, like coffee cups, but the mooted solutions are very broad brush, particularly Extended Producer Responsibility (EPR) reform.
EPR concepts are becoming increasingly mainstream, and while Europe has led the way in this arena, the legislation dates back to the 1990s. Within these established systems, parochial quirks of implementation and unintended consequences have been given the opportunity to develop and become entrenched.
A particular challenge lies in matching obligated manufacturers to their fair share of what it costs to collect and recycle both products and packaging. The scope of what is included within producer responsibility varies between countries and regimes, the funding (and responsibility for) the collection of waste products and packaging from householders being a costly flashpoint for difference of opinion.
EPR system for packaging in the UK
Our EPR system for packaging in the UK is unique. Manufacturers must buy so called ’Packaging Recovery Notes’ (PRNs) from accredited recyclers of packaging, in effect a recycling credit, to demonstrate that they have funded sufficient recycling to meet their share of the overall system costs. The idea being that, under free market principles when conditions are difficult and demand is high for recycling credits in the recycling system, PRNs are expensive. When conditions are easy and demand is low, PRNs are cheap, which allows the right about of funding to enter the sector. Also, the theory says that financing through the back end of the network will provide a system pull and the funding will trickle through.
This has not worked out in practice and in the UK, EPR does not extend to the financing of collection from householders, which remains a concern of local government. Adding further complication, different parts of the packaging supply chain are obligated to buy PRNs, not just the manufacturer selling packaged product, and the UK has a greater number of compliance organisations than in any other system worldwide.
This fragmentation and complexity means that no one has a measured and crosscutting view of the whole system. True cost data is impossible to determine and a number of stakeholders, when feeling the pressure, are sat in their silo convinced that they are getting a bad deal. There could well be some truth in this, but the only analysis presently available that speaks to this issue is dated and partial, which is unhelpful.
Focusing on the fundamentals of Extended Producer Responsibility
If EPR is to be reformed in the UK, and we feel that it should, the conversation needs to take place in the right forum, it should recognise the interests of all stakeholders in the system and focus on the fundamentals of EPR:
- Manufacturers and retailers should take responsibility for the full lifecycles of the products that they sell.
- The polluter should pay for the waste generated by their products.
The attempt should be bold enough to challenge entrenched orthodoxy of the current approach to allocation of responsibility and costs. An independent, mediating body, can take the heat and the attrition out of the matching process and ensure fair operation and there are successful models to reference both in the rest of Europe and beyond.
If international best practice is sought by policy developers as a reference point, and we think it should be, it should be drawn from practical experience of these systems, and not just the theory. Nowhere in the world are manufacturers writing blank cheques to Local Government, but that doesn’t mean that the burden cannot be shared more equitably.
There is the opportunity and the mandate to reimagine the UK EPR systems as something progressive, efficient and effective. It is time for objectivity, pragmatism and a system wide and balanced view.
You can also read more about the plastic sustainability challenge here.
You can also download our Sustainable Packaging Solutions two page guide.