UK producer responsibility regime recast

  • techUK techUK
    Tuesday19Mar 2019

    A suite of consultations from government seeking to reframe how we manage and handle packaging in the future will have implications for the future management of waste...

The consultations, which include a root and branch reform of the UK packaging producer responsibility system and a new plastic packaging tax, proposes a major departure from the status quo. The deadline for responses is 12 May.

The premise of producer responsibility is that manufacturers assume responsibility for the management and costs associated with the collection, treatment and recycling of their products when they become waste. The existing producer responsibility system for packaging in the UK represented one of the lowest cost regimes in Europe with only 10% of end of life costs being picked up by producers.

Concerns around the governance of the UK system, alongside the low financial contributions from producers, increasing public concern regarding plastic and new recently agreed European requirements has led to a very detailed, complex root and branch review of the system.

Government has confirmed that decisions made on the governance of the packaging system, will shape future reforms of the UK regimes for waste electronics and batteries which will be reviewed later this year, and consulted on in 2020.

It is difficult to summarise the content in a blog – nearly 200 questions are asked in just two of the consultations – but some of the key aspects of the proposals include:

  •          Producers to be responsible 100% of costs at end of life, including costs associated with littering, flytipping, communications to the public.
  •          Producers that produce more environmentally friendly packaging will face lower compliance costs than others via modulated fees.
  •          Rather than sharing responsibility for the cost of compliance along the supply chain, the government is exploring a single point of compliance, either the brand/importer or seller.
  •          Online platforms to be defined as a new type of producer and assume responsibility for the packaging they facilitate the sale of.
  •          Clear labelling to consumers as to what can or cannot be easily recycled.
  •          A potential departure from the competitive producer compliance scheme structure, with options including a single management body or a new system based on deposit returns.
  •          A new packaging tax for any plastic packaging which does not contain at least 30% recycled packaging. Currently it is proposed that this will impact unfilled packaging.

techUK is working closely with members to consider the proposals in detail. But even if you do not wish to engage in the consultation in detail, we are interested in views from members on the following questions:

  •          Is a single point of obligation (compliance), e.g. Brand Owner, or Seller/Importer, desirable? Which would you prefer?
  •          Does a placed on the market deposit-based system, where producers pay an amount when placing products on the market and recover a returnable deposit based on proof of recycling, have any merit?
  •          Could the development of an approved list of materials based on recyclability underpin modulated fees or a deposit-based system?
  •          Should online market places be obligated for products that they ‘facilitate for sale’ in the UK?
  •          Should recycling and waste targets be set on a nation by nation basis (England, Scotland, Wales, Northern Ireland) and would you be able to provide nation specific placed on the market data?
  •          Do you have strong views on the future governance model that should be adopted? What in your view are the pros and cons of the various models proposed?

If you have views, we are happy to arrange a call or accept written contributions to inform the techUK response. Deadline for comments is Friday 5 April. For a more detailed briefing on the consultations please contact or join techUK’s Waste and Resources Mailing List.

  • Susanne Baker

    Susanne Baker

    Associate Director | Climate, Environment and Sustainability
    T 020 7331 2028

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