Page 27 - PWM2024_APRIL EBOOK

TECHNOLOGY REPORT

especially would increase significantly.” “There is no indication as to what these base and eco-modulated delayed.
He dismisses the argument that mov- fees will be, which makes it impossible for companies to budget.” But the real issue, in Clark’s view, is
ing the responsibility will move cost on, He notes that the government’s aim is to cut the amount of pack- that there is a great danger that “some
saying that the cost of collecting, sorting aging used and to switch to more sustainable and easily recyclable companies who should have been regis-
and recycling packaging is presently materials such as fibre-based materials while increasing the tered under the current Packaging
paid for through Council Tax meaning amount and quality of recycling – this suits products made with Waste Regulations have not done so
that shifting the responsibility onto pro- paper and card but not necessarily others. through ignorance of the requirements
ducers should help taxpayers: “Do we From an alternative standpoint, Girling and WRAP believe in and this will be highlighted under EPR
think that if this happens then our the EPR system precisely because it “is progressive, capturing reporting”.
Council Tax will reduce? I very much more packaging placed on the market than the former system” Questionable rules?
doubt it.” and because it “also allows for the introduction of integrated regu- The EPR rules have, according to
Clark emphasises that the cost of EPR latory mechanisms that make the system fairer overall”. Here he’s
should “not be borne by the packaging talking of the eco-modulation that Clark has just referred to. Clark, the potential to place a huge
financial and administrative burden on
industry as it is so huge – it is estimated Girling thinks that it’ll lead to producers placing easier to recycle the packaging industry. He says that pro-
to be around £2bn per annum”. He reck- packaging on the market and will be rewarded with discounted tecting the environment is one thing,
ons that ultimately the cost of EPR will EPR fees and conversely, producers placing harder-to-recycle but he has concerns about unintended
filter down to consumers through higher packaging on the market incentivised to move to more recyclable consequences, such as an increase in
prices of goods. packaging through increased EPR fees. food waste if packaging formats are
But taking an opposing stance, Girling Clark takes a moment to explain that the BPIF has been pushing changed to reduce the impact of EPR
believes that while the costs for packag- for separate collections for paper and card as a means of improv- fees.
ing waste management will increase for ing still further the quantity and quality of recycling. He’s adamant when he says that “the
‘producers’ under the EPR system, “the “Unfortunately,” he says, “the government will not instruct local EPR scheme certainly is not ready”
costs of packaging waste management authorities regarding separate collections of paper and card leav- which is why there have been delays in
are not necessarily increasing overall; ing it up to the councils to carry on with co-mingled collections if implementation; “it is only recently that
EPR: is it workable? tributed to the companies that are plac- that is their preferred option.” He’s not happy that some paper appointed for the next two years and it is
a scheme administrator has been
the existing costs are simply being redis-
and card could be lost through landfill or incineration.
expected that an operation of the size of
ing the packaging on the market in the
Clark also highlights the fact that most fibre-based material col-
first instance”.
in place to fully implement EPR”.
He does recognise that there are addi- lected in the UK must be recycled abroad due to the lack of UK a FTSE 250 company will have to be put
recycling facilities. This is why he says that “we must be aware of
tional costs to set up the new system and the requirements that the foreign recycling plants maintain – the Clark adds that “the EPR has been
that costs will increase as targets are UK cannot go it alone”. He contrasts the position in Europe and talked about for years; the performance
increased. However, Girling takes the the UK: “In most of Europe separate collections of paper and card of Defra and the Environment Agency
line that “placing 100% of the costs on are the norm... but in the UK waste is a devolved issue so it is possi- has been disappointing to say the least
with huge time delays in responding to
the companies placing the packaging on ble, even probable, that different rules could apply in the home various consultation processes and a
the market means that those companies nations; this must be avoided.” total lack of clarity in the requirements
are more incentivised to make the pack- of the scheme”. These rollbacks are caus-
aging more manageable”. Who has responsibilities under the EPR? ing confusion. But in response, Girling
As to the practicalities of EPR, the theory is that brand owners
How will the government achieve should pick up most of the costs. But Clark is concerned that pack- tells that last summer the fees payable by
its goal? aging suppliers could be responsible if they act as a ‘distributor’ of producers under the new EPR system
EPR fees are to be calculated on the packaging to companies that are below the de-minimis thresh- were deferred from October 2024 to
October 2025 so that Defra could use the
cost of collection, sorting and recycling olds. “This,” he says, “will put a huge strain on packaging suppliers additional year to conclude the design of
of packaging based on the net cost to as they will have to find out if their customers are ‘small’ within
local authorities. But Clark worries that the definitions of EPR; this will be a huge administrative burden.” the EPR system. He also considers it
there is a grey area in relation to how In overview, reporting for large companies that have a turnover noteworthy that while the EPR fee pay-
efficient local authorities will have to of more than £2m and handle over 50 tonnes of packaging a year ment obligation was deferred for a year,
become as “effectively they could have a will be required twice a year. While this requirement came into the rest of the new system was not. As a
blank cheque, with costs met by the force in March 2023 Clark comments that “due to the lateness result, Girling advises that “producers
packaging industry”. and uncertainty regarding reporting obligations if companies need to report under two systems – old
And then there’s the matter of cost report their 2023 date by the end of May 2024 they will not be and new – in parallel” which will add
calculations where base costs for each prosecuted”. He points out that payments under EPR will start in administrative burden. Even so, a par-
material type will vary, with a further 2025 and companies with a turnover of more than £1m handling ticular bugbear of Clark’s is that those
eco-modulated fee applied to materials between 25 and 50 tonnes of packaging will have a reporting obli- expected to pay the bills under EPR –
that are easier or more difficult to recy- gation which did not exist before. namely the packaging industry – “have
cle. It doesn’t help with confusion in the trade that, as Clark points for the most part been ignored during
At the time of writing, Clark says: out, Nation of Sale data reporting has also recently been further the process to date.”

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