Government Proposed Extended Producer Responsibility (EPR) Regulations

Written by Lee Sheppard, Director of Corporate Affairs, Policy and Sustainability at apetito | Wiltshire Farm Foods.

The UK Government is embarking on a period of challenging packaging reform. From the Plastics Tax, through Consistent Collections, Deposit Return Schemes (DRS) and Extended Producer Responsibility (EPR), one can see this as a once-in-a-generation opportunity to improve how we influence how packaging is dealt with.

The ambitions of these schemes are laudable – we all agree that we have to limit the impact of excess packaging and foster an environment that focuses on reducing packaging, promoting its reuse and ensuring that recycling rates improve.

At apetito we applaud and share this ambition. We also accept that such an ambition will not always be met with agreement by all parties involved; such is the nature of Government legislation, but we need to be bold and we need to tackle this challenge before it is too late

However, that importance of this “ambition” should not be allowed to ride roughshod over the importance of working to deliver the very best solution.

With Extended Producer Responsibility (EPR) many fear that Government is ploughing blindly on with its own plans, deaf to the ears of an industry eager to help. Without attempting to tackle every single challenge of the Governments proposed implementation of EPR (and there are many), I'd really like to tackle the planned approach to how they will address world-leading producers that have introduced closed-loop recycling systems that deliver results far better than the Governments plans to support kerbside recycling.

It is estimated that EPR will add more than £60 per annum to average household shopping bills. On that basis, at the very least we have a right to demand an excellent model. Therefore, I have to ask why do Government plans include taxing companies that have developed highly effective closed loop recycling systems that place absolutely no burden on local authority waste collection – when this will result in higher prices to consumers when they can least afford it?

We have committed significant investment to our “Project Boomerang” which we believe to be the world’s first closed-loop recycling system for ready meal trays - we know this delivers far superior environmental results when compared to kerbside recycling.

Under current proposals, the Government is proposing to tax a successful and innovative company for waste that is not being put into the local authority system – which is patently unfair.

Why wont Government support our system?

When challenged, Government state they do not plan to “exempt” our system under EPR as “EPR will not allow for offsetting of packaging where it is collected by more than 75% of local authorities, as it risks reducing “system efficiency.” Plastic trays are collected by more than the required 75% so therefore they reject our request for exemption.

However, we fundamentally disagree with their response as it is completely missing the point.

As stated, we absolutely support the ambition of EPR, and have some understanding of why Government want to avoid duplication of systems, However, it is disingenuous for them to compare their uncertain future hopes of what EPR might deliver against the hard facts of our current closed loop system.

Let me explain why I believe our scheme is a far better solution than kerbside recycling:

Collections

• After years of operation, only 38% of “Plastic PTT” (Pots, Tubs, Trays) (1) are collected from households. One year in, our system is seeing rates closer to 50% and these are growing rapidly. Quite simply, we have a direct relationship of trust with our customers and therefore will always deliver better collection rates.

Recycling

• Collections are just the first stage in the journey, we then have to look at how much of that collected is actually recycled.
• Recoup report that 47% of UK collections for recycling are actually sent abroad for processing (1). Various reports highlight concerns with the effectiveness of this approach – highlighting some of the recyclate simply being burnt for energy recovery and some ending up in landfill. We however guarantee that 100% of trays we collect will be reformed into new trays, a far superior result.

Reuse

• We guarantee that 100% of our trays are reformed into new, with each new tray containing 80% recycled content. Therefore, our system is arguably closer to “re-use” than “recycle”.

The results above show that the Governments approach will deliver poorer environmental results by rejecting an outstanding system and replacing it with one that remains no more than a future ambition.

Our challenge back to Government is simple and clear:

•  For now, allow us to continue with our world-leading closed loop meal tray system and do not penalise us under EPR by taxing us for any trays that we collect.
• If, and when kerbside collections get to a point where they deliver better environmental results, then we will happily engage with and support that system – and if we don’t, then we fully support paying tax under EPR.

Defra state that “Our mission is to restore and enhance the environment for the next generation, and to leave the environment in a better state than we found it”. Let’s support all innovative producers that align to that vision.

Lee Sheppard

Director of Corporate Affairs, Policy and Sustainability at apetito | Wiltshire Farm Foods.