Single point of compliance:
The first and main key difference between the two systems is the point of compliance. EPR levies 100% responsibility for a piece of packaging on one producer, whereas in the current system the responsibility for one piece of packaging is spread out across the supply chain.
Local Authority Costs:
The financial burden of kerbside collections currently sits with the taxpayer however, Extended Producer Responsibility will transfer this responsibility to obligated packaging producers by requiring a Local Authority waste management fee. This fee will be paid from producers to the scheme administrator and redistributed amongst Local Authorities.
Full Net Cost:
Where the current system only subsidises UK recycling through the purchasing of recycling evidence by obligated producers (PRNs), EPR will fund the full net cost of collection, treatment and sorting of packaging waste.
Defra will look to introduce modulated fees for each packaging material in 2025. Modulated fees determine the cost an importer or brand owner pays for a type of packaging depending on certain characteristics such as environmental impact of its production, recyclability and the life span of the material used. The more recyclable a material, the cheaper it will be under Extended Producer Responsibility.
Lower threshold for compliance:
Currently obligated producers are companies who have a turnover of £2m per year and place 50T of packaging onto UK markets. Under the new system companies who hit this threshold will be referred to as ‘large producers’, and companies who have a turnover of £1m per year and place 25T of packaging onto UK markets will be referred to as ‘small producers’ and will be brought into scope for packaging compliance for the first time. ‘Small producers’ will have a data only obligation and will be required to submit packaging data just once a year.
In the current system, obligated producers are required to submit packaging data once a year to generate their recycling obligation i.e. How many P(E)RNs they will need to purchase in order to comply. Under the new system, producers will report granular data twice a year with the packaging material, weight and type as well as packaging activity, waste type and for some producers the nation of sale of each piece of packaging. These twice a year EPR reports will produce both a PRN recycling obligation, and a household waste collection and management fee.