Response to the consultation on reforming the UK packaging producer responsibility system

Regional Centre for Expertise Cymru

Response from the Circular Economy Research and Innovation Group (CERIG) for Wales

The Circular Economy Research and Innovation Group (CERIG) for Wales welcomes the opportunity to comment on the Consultation on reforming the UK packaging producer responsibility system (referred to hereafter as ‘Packaging EPR’). CERIG views the reduction, reuse and recycling of packaging as being essential to the delivery of a more economically, socially and environmentally sustainable UK.

Below we provide comments on the Packaging EPR Consultation. These are divided into two sections. First, an introduction that provides an overview of CERIG and secondly our primary points for consideration in the development of the Packaging EPR as it currently stands.

  1. Introduction

CERIG was set up in June 2018, with the aim of connecting complementary expertise and experiences to facilitate circular economy innovation and research in Wales. This is to be achieved through the following objectives:

  • Establishing a forum to share good practice and facilitate knowledge exchange between academia, business and policy makers.
  • Encouraging and supporting collaboration to increase circular economy research capacity in Welsh institutions.
  • Engaging with industry to develop industry led research.
  • Providing evidence to inform Government policy and programmes.
  • Showcasing Wales’ circular economy outputs internationally, thus supporting the development of international partnerships.
  • Collaborating on curriculum development and training.
  • Working with the Global Regional Centre of Expertise (RCE) network (acknowledged by the United Nations University) to share learning and good practice at regional, national and international levels.

Membership of CERIG includes higher education institutions in Wales and representatives from business support providers and Welsh Government. The comments presented in this response have been developed by a CERIG working group and individual members may submit additional responses to the consultation.

  • Key Considerations

We welcome the spirit of the consultation and recognise the timely opportunity for UK and devolved governments to enable significant changes to the way packaging materials are produced and used as part of the UK’s commitment to minimising environmental impact, addressing climate change and enabling a more effective use of resources.

Overall, we are supportive of the development of a packaging EPR but believe that there are a number of areas that require further development as highlighted below:

  1. Whilst we recognise the value of recycling and designing packaging to be recyclable, including compostable packaging, we are concerned that the Packaging EPR currently has limited scope in being able to address the principles of the waste hierarchy. On this basis, we do not agree with the proposed principles for the packaging EPR and its focus on recycling (Q6). Our position is that the waste hierarchy must be embedded within the principles, in line with the EU Waste Framework Directive[1], to avoid lock-in of recycling systems, practices and infrastructure that has the potential to inhibit innovation in alternative material use and design, product design, research and alternative economic and systems models of production and consumption. We strongly recommend that encouraging reduction of packaging and supporting better packaging design, such as design for reusability and alternative lower environmental impact materials, should be an overarching primary principle. We also propose that the adoption of eco-design principles, and concepts such as lifecycle assessment, are important in deciding what constitutes ‘better packaging design’ in any given context[2]. This overarching principle is a common feature reflected in the comments below.
  2. We support the need to be clear on outcomes for the Packaging EPR. However, we do not advocate the outcomes proposed to date (Q7) based on a lack of consideration of the waste hierarchy (see above) and the lack of clarity in the definitions currently proposed in the consultation document. We strongly recommend that definitions of key terms such as “packaging”, “unnecessary”, “difficult to recycle”, “recyclability” etc. are made specific, used consistently and are universally applicable for all producers and users of packaging material[3].
  3. We are supportive of all types of products that can be understood to be a form of packaging to be incorporated into the EPR. This includes single use packaging sold as a product for use in the home. On this basis, we would support such material being legally considered as packaging (Q8) given that such packaging may form a component of packaging material in residual waste streams that could potentially be better designed and managed. This approach would be supportive of acknowledging everyone’s role in addressing packaging type material waste issues, ensuring the general public shares part of the “polluter pays” obligations, and encourage changes in “eco” purchasing decisions. However, we would anticipate the obligation would be on producers of the products placed on the market to encourage development and availability of better designed packaging, such as multi-use, lower environmental impact materials, recyclability and recycled content.
  4. Concerning Q10, continued funding for research, innovation and commercialisation of new technology, processes and mechanisms for societal change is needed. This will help develop more effective mechanisms to address the waste hierarchy and monitor the effectiveness of implementation of policy or legislation in this area. We are open to whether this is funded through full net costs as part of the Packaging EPR, or though other mechanisms[4].
  5. Progress towards a circular economy requires a thorough understanding of material flows and their short- and long-term environmental and social impacts[5]. For Q10 &11 we believe that there is a lack of data and transparency on materials flows at national and international levels, to enable the identification of opportunities for effective implementation of the waste hierarchy, e.g. facilitating industrial symbiosis, slowing loops or effective open loop recycling of alternative materials[6].Although this may require investment in data management that goes beyond the needs of the Packaging EPR, it is essential that funding for collation and dissemination of this data is identified and that any data management system for EPR is specified so it facilitates the collection of this data for all packaging material flows. The EPR scheme should be designed in order to ensure that businesses involved in value chains putting packaging onto the UK market are incentivised to participate, and to widely adopt the outcomes of such strategies. Again, we are open to whether this is funded through full net costs as part of the Packaging EPR, or though other mechanisms.
  6. We fully appreciate the current reasoning for excluding commercial and industrial packaging from the scope of full net cost recovery, given the current focus of the proposed EPR on recycling. However, we firmly believe that more is required of commercial and industrial packaging both in relation to moving up the waste hierarchy, and good quality data collection, due to the volumes placed on the market[7].Therefore, in response to Q12, we support that commercial and industrial packaging should be included with the intention of encouraging better design in products and packaging in order to reduce material use and overall environmental impact. Better packaging design could include: design for reusability and overall packaging reduction/ elimination thus reducing material use; inclusion of recycled content; alternative materials with lower environmental impact and reduction of single use materials such as shrink wrap. Options would require effective evaluation of overall environmental benefits of change for the complete lifecycle of the products, taking account of other policies, such as promoting shifts in transport fuel use to low carbon electric that may negate current arguments against concepts such as reusable transit packaging.    
  7. We are supportive of action to encourage appropriate use of DRS schemes and appreciate the complementarity of such schemes in supporting a move to reduce packaging material consumption. If a DRS scheme is introduced for disposable cups/drinks containers and other forms of food and beverage containers, there is still a responsibility to deal with such containers that are not captured through this route and end up in the household waste stream or as litter. Regarding Q13, we would support further considerations of where the responsibility for dealing with such “lost” containers lies. We consider it important that there is an obligation to deal with such “lost” containers either through the packaging EPR or as part of the DRS, but not both.
  8. On Q14, we are generally supportive of approved lists. However, we strongly believe that approved lists must reflect the best environmental strategy from a whole lifecycle perspective, and not just current economic, embedded or pragmatic strategies, to support the waste hierarchy. For example, any lists must take into account the environmental impact of materials and reusability of packaging materials and encourage the development of products where packaging should be designed out, designed for reuse, or designed to limit environmental impact throughout the material lifecycle. The list should be regularly revisited to reflect technology improvements /innovation, global material flows and changes in societal behaviours and demands.
  9. We are supportive of the ambition for finance obtained through an EPR obligation to cover the full net system costs of managing packaging waste. Analysis of Packaging EPR across Europe has shown that such schemes are successful in increasing recycling rates, but have limited effect on the adoption of measures that address the prevention or reuse of packaging materials[8]. Although our preference is to adopt a modulated fees approach (Q15-17), we believe that this should be an ‘eco-modulated fee’. We recommend that such fees should: 1) be  proportionate to the environmental impact of specific packaging types during production and end of life, being consistent with other schemes like emission charges, and 2) encourage better design of packaging to address higher levels of the waste hierarchy, e.g. reusable packaging and reducing packaging overall. On Q16, we consider that the unintended consequences of a focus on recycling related fees only will include limiting the opportunities for innovative and environmentally sensitive alternative packaging, product and service design that may have the potential to eliminate or significantly reduce the need for packaging.
  10. We believe that encouraging behaviour change throughout the supply chain from producer to end user should be part of the requirements of the EPR, as it affects understandings of the obligations. We are supportive of obligations being applicable to all stakeholders in the packaging and product supply chain (Q19-23). In relation to Q20, we would support obligating small and micro businesses (including mobile food businesses) in some capacity. Our preference for how such an obligation should be introduced is for a version of option B, where the primary obligation is on distributors (Q21). However, we would suggest considering placing an onus on micro and small businesses engaged in “on the go packaging” to contribute to local issues regarding littering and communications. We would recommend the consideration of options similar to the carrier bag charge approach, or a flat fee incorporated into business rates commensurate with size of operation, as a contribution to aspects such as littering and communications.
  11. We are pleased to see that the growth in online marketplace practices and its potential impact on packaging use and waste is being considered in the EPR as packaging from online retailing is an important issue, given the significant growth in parcel packaging in recent years[9]. We understand that the proposed obligations relating to Q25, are associated products and packaging originating outside of the UK, sold to UK users thorough a facilitated online marketplace. We are assuming that products and packaging from sellers in the UK will already be captured through the EPR. On this basis, we agree that the online marketplace is to be subject to the polluter pays principle. However, the position of online retailers needs to be further explored due to the complex and varied business models involved. For example, how would products obtained directly from organisations based solely outside of the UK, not through a facilitated platform, be addressed?
  12. Following on point g above on disposable containers, relating to Q34, we would support making mandatory, rather than relying on a voluntary arrangement, the requirement on businesses over a certain threshold that dispense food and drink items in disposable containers, to take back such containers, irrespective of the type of material, and provide facilities for customers to use reusable containers. However, we would consider it also appropriate that all businesses irrespective of size be mandated to allow customers to use reusable containers.
  13. We have concerns that there may be insufficient mechanisms of validation or control of claims of compliance with the proposed outcomes of the EPR, particularly levels of recycling achieved, recycled content, recyclability (including compostability) and moving up the waste hierarchy. We consider that there is a necessity for the development of appropriate standards for: the monitoring of quality control; establishing a “level playing field”; the provision of robust information throughout the supply chain; the creating of markets for better designed packaging and the elimination of packaging, and supporting innovation in product and packaging design. The environmental impact of products and their associated packaging based on a whole life approach should be assessed as part of this. Whilst this is good practice for all packaging, it is particularly important when considering the packaging of food and other perishable goods where waste arising from product loss may offset any gains from packaging waste reduction[10].
  14. We recognise that recycling targets have a role in encouraging increased recycling and demonstrating a direction of travel on managing waste. However, focussing on just recycling targets limits the ability and incentive to address the waste hierarchy, such as reusability and overall reduction in packaging, and rethink product and packaging design, types of materials, management and systems to reduce overall environmental impacts. Robust data on materials flows will provide an evidence base to inform a wider range of targets and monitor progress. Regarding Q48-50, the UK Government and devolved governments are in a unique position to influence a concerted move, in support of global, national and local social movements, to address overall material use and waste production. We believe that there is an opportunity to be at the forefront of major change by incorporating targets that address more than the end of life of packaging materials. We strongly recommend that targets and mechanisms are incorporated that encourage overall packaging reduction and better design of packaging and systems, considering a life cycle approach. Furthermore, recycling targets should be based on materials actually recycled and known materials flows, rather than based on data related to what is sent for recycling given that there are ambiguities in the current data collection methods[11]. In addition, municipal, commercial and industrial packaging waste should all be included within the targets.

We hope that these comments are of value in the development of the Packaging EPR. Furthermore, CERIG and its individual members would welcome any opportunity to help support the development of the Packaging EPR further, following the consultation.

Response from the Circular Economy Research and Innovation Group (CERIG) for Wales

Dr Gavin Bunting (Chair of CERIG and Associate Professor, College of Engineering, Swansea University)

Ann Stevenson (PhD circular economy researcher, School of Psychology, Cardiff University)

Dr Katie Beverley (Senior Research Officer, PDR, Cardiff Metropolitan University)

Dr Nick Hacking (Lecturer, School of Planning and Geography, Cardiff University)

Susan Jay (Circular Economy Technical Specialist, WRAP Cymru)

Gary Walpole (Director – ION Leadership, Swansea University)

Supported by:

Andrew Hopkins (Strategic Technology Manager, School of Engineering, Cardiff University)

Dr Rhys Charles (Research Officer, College of Engineering, Swansea University)

Jay Doyle (Research and Business Engagement Officer, College of Science, Swansea University)

[1]   The EU Waste Framework Directive was amended in 2018 to take into account recent developments in Circular Economy policy:  The amendments acknowledge that ‘ make the economy truly circular it is necessary to take additional measures on production and consumption by focusing on the whole lifecycle of products in a way that preserves resources and closes the loop

[2] Pauer et al. (Sustainability: 2019, 11 (3), 925) argue in their recent study on food packaging and waste ‘..the transition towards a circular economy is not a goal in itself; it should deliver ecological goals.  Packaging designers should always apply life cycle thinking to verify that e.g. improved recyclability in fact contributes to the overarching goal of reduced environmental impacts’.

[3] For example, it is unclear whether reduction in “unnecessary” packaging is at a product or systems level.  Further, if it is considered “unnecessary” it is not clear why the goal is reduction rather than elimination of such packaging. In addition, the use of terms “unnecessary” and “difficult to recycle” have already become contested terminology within the packaging sector.

[4] Such as the forthcoming ‘Smart, Sustainable Plastic Packaging’ Challenge

[5] There are currently significant knowledge gaps in this area (see, for example, Korhonen et al. (Circular Economy: The Concept and its Limitations, Ecological Economics: 2018, 143, 37-46)

[6] The National Audit Office identified significant weaknesses in existing data collection for both household and commercial packaging placed on the market:  A recent report also posited potential issues with the current collection of packaging data:

[7] The National Audit Office expressed particular concern regarding the quality of data within the commercial and industrial sector.  “…waste collectors in the commercial and industrial sector are not required to submit data on the waste they collect. The Department [Defra} told us it recognises this as a key area of uncertainty and that it speaks to stakeholders to improve its understanding of this sector”.

[8] See: 1) (Rubio et al., 2019; Institute for European Environmental Policy, 2017; and 2) Zero Waste Europe, 2015:

[9]Ofcom data shows that domestic parcel volume increased by 5% in 2014/15, 13% in 2015/16 and 9% in 2016/17 (

[10] A recent study by Pauer et al. (Sustainability: 2019, 11 (3), 925) recommends adopting an extended life cycle approach to identify trade-offs that may be necessary in order to manage competing sustainability objectives, including balancing packaging waste impacts with food loss impacts.  WRAP’s Courtauld Commitment, a voluntary agreement aimed at increasing resource efficiency in the grocery sector, has also worked to balance these twin impacts throughout its development:

[11]The Packaging and Packaging Waste Directive allows data to be reported in terms of the output of a sorting plant, provided ‘it is sent to effective recycling or recovery processes without significant losses’. It is not made clear what is considered ‘significant’ in this context.  Further, there is a lack of traceability regarding materials sent abroad for recycling or recovery.   Produced by:


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