Government launches second round consultations for EPR and DRS

The second round of consultations for Extended Producer Responsibility (EPR) and the introduction of a Deposit Return System (DRS) were released yesterday (24th March 2021), but without the expected accompanying consultation on consistency of collections.

Following the initial consultations and the responses, released July 2019, the expected consultations for the resources and waste sector faced multiple delays from general elections, Brexit and the covid-19 pandemic.

Extended Producer Responsibility consultation

The EPR consultation covers 15 separate sections with 104 questions for stakeholders to respond to. This is accompanied by an impact assessment, which models various cost analysis of the proposed legislative changes. The consultation sets out various scenarios, many built upon the initial consultations and the responses for the future landscape of packaging compliance.

The proposal outlines the phased introduction of EPR, beginning in 2023 and continuing to have additional measures brought in over 2024. The consultation gives producers a general idea of how modulated fees, labelling, administration and data reporting and requirements will be managed and enforced but will also allow stakeholders to feedback on the proposals should they have insight or concerns.

Deposit Return System consultation

The DRS consultation covers 10 chapters, detailing areas from the scope of the scheme to the financials flows of the system. The 78 questions will allow stakeholders to understand the current proposals for a Deposit Return System in England and for feedback in areas that stakeholders may be able to give further insight and development. The timeline provided in the consultation is now looking at implementation in 2024, as opposed to the initial rollout in 2023.

The consultations run from now until 4th June, this is a shorter timeframe than the standard 12 weeks for government consultations, allowing 10 weeks for stakeholders to share their views.

Respond to the EPR consultation here:
Extended Producer Responsibility for Packaging – Defra – Citizen Space.

Respond to the DRS consultation here:
Introducing a Deposit Return Scheme in England, Wales and Northern Ireland – Defra – Citizen Space

Commenting on the proposals outlined in the consultations, David Honcoop, Founder and Managing Director of Clarity Environmental, said: “We are firmly behind the environmental principles of the reforms but there is understandable concern about the proposed timelines, particularly given the delays experienced since the first consultation. The failure to publish the Consistent Collection consultation alongside these documents also leaves a level of uncertainty about how the policies will connect.

“Producers are likely to see significant increases to the cost of their compliance, which look to be higher than previously forecast. We are concerned about a number of proposals that could reduce competition in the compliance and collection systems, as there is evidence that this could lead to even further increases, as has been documented in international studies.

“We want to support the UK to achieve a greener, more sustainable post-pandemic recovery, and we are seeing great progress and innovation from producers. But it is vital that businesses are supported by the right data, research and infrastructure that will ensure any decisions taken on packaging achieve the best possible outcomes for people and the planet. With the consultation asking for feedback on a phased timeline, it is important to review whether this provides adequate time for the industries concerned to do just that, whilst allowing them to grow and thrive.

“The scheme administrator now has less than 24 months to be tendered and established and there are some concerns over how this will be implemented, with enough time to adequately prepare for the sheer scale of operations.”

We will be looking at how best we can support our packaging compliance members in understanding the content of these consultations and how they will impact compliance. We are urging as many businesses and individuals as possible to take this opportunity to influence the future packaging landscape and respond independently, even if represented by a trade body.

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Extended Producer Responsibility (EPR) and Deposit Return System are two of the four ongoing areas of reform to the UK & Resources Waste strategy alongside Plastic Tax and consistency of waste collections, which will have a phased implementation from 2023 and will have a huge effect on those who place packaging onto the UK market. Our in-house specialists are here to support packaging producers through legislative change, and can explain how they could impact your business. From forecasts, to webinars and training, we can help you to future-proof your packaging, ensuring compliance under new regulations whilst enabling your business to grow.

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Join our webinar: Extended Producer Responsibility

The deadline to respond to the consultation on Extended Producer Responsibility is 4th June 2021, giving stakeholders only 10 weeks to formulate their responses. In the first of a series of webinars our team at Clarity Environmental will help to guide you through the sections relevant to producers, where your input will be most valuable and understanding the implications of the consultation on future compliance.

Join our Webinar