INDUSTRY COMMENT


EPR – is it worth it?


Martin Kersh, executive director, Foodservice Packaging Association (FPA), asks is the pain of packaging EPR really worth it?


T


he vending sector has always been a very important market for foodservice packaging, especially for paper-


based coffee cups. Despite the effectiveness  as a key part of the food and drink sector, vending has been greatly underestimated by governments in their packaging policy


developments. The UK’s packaging producer responsibility system in the form of packaging Extended Producer Responsibility, is shifting up many gears in terms of its requirements of businesses and, although it has been many years in the making, businesses only recently have been waking up to what is involved. The wakeup call has been in the form of the substantial increase in


producer responsibility fees, coupled with the enormous increase in the administration required to meet the requirement of submitting data under packaging EPR to the Environment Agency. The latter is a legal requirement, fraught with a considerable number of hurdles to trip-up those completing the information. Incorrect completion can result in data submissions being rejected, potentially leading to a business being removed from the all-important register of organisations submitting data. Added to this is the policy of charging packaging EPR fees by


packaging weight. This to me is nonsensical, because the number of bottles in a tonne of glass bottles is considerably fewer than a tonne of plastic bottles of the same size. This type of discrepancy is repeated across other materials, resulting in producers who had previously welcomed EPR now deeply suspicious that the packaging marketplace is being severely distorted, and concerned about competitor materials gaining market share at their expense.


A further impact of the weight-based fee structure is the reversal of the


growth of so called ‘more sustainable’ packaging formats, encouraged over the years by governments and already being observed. We also have to consider the impact of a responsibility system which only applies to part of the market. Data doesn’t need to be submitted for a business placing under 25 tonnes of packaging on the market and with an annual turnover of under £1 million, while  life even more complex, because obligated businesses then need to know the turnovers of their customers and, given the complex supply chains, that of their customers’ customers. It seems to have come as a surprise to government that businesses aren’t inclined to hand over the names of their customers to their suppliers, nor to make their suppliers aware of the share of their business they are supplying. Under the system all packaging has to be accounted for, so this minimum qualifying level means those who have to pay are subsidising those who don’t. Mary Creagh the minister responsible, while stating the minimum qualifying level excludes 70% of businesses from paying fees, claims this is costing obligated businesses little extra. Removing smaller businesses from the process doesn’t remove


them from the cost, as suppliers will be forced to pass on all the charge to their customers if they are to remain in business. This is exacerbated where margins are thin – unbranded empty packaging being a case in point. Inevitably the charge is ultimately passed on to the public, who are already facing ever-increasing council tax bills, which currently cover household waste management costs. So, what we actually have is a huge increase administration, confusion and uncertainty, market distortion, and a reversal of government intentions. Not to mention the increasing lack of  admitted by Defra, the strong likelihood there will be no increase in packaging recycling by 2030. We will never know why the government didn’t simply tax


packaging at source, the admin of which could have been managed by a bookkeeper. When faced with a choice it seems the more complicated and least effective option again wins out. Regrettably a cost that will be borne by you all.


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