Extended Producer Responsibility: what is required for success?

During the event on 18 July, run by Policy Connect, Robbie spoke about the key factors for the success of EPR regimes.

As part of a panel of five speakers from across the industry, Robbie mentioned that Ecosurety have been actively campaigning to try and change packaging legislation for a couple of years. He highlighted that “It’s been really heartening to see the appetite within government at the moment to change it. We also definitely welcome a review of things like the WEEE regulations, and how they could be made better at the same time.”

Robbie started his talk by stating that a UK wide system is key across all EPR regimes. “Things like plastic bags and the single use carrier bag charge is totally appropriate for devolved governments to go for, but there are certain things that are not appropriate, and I would agree that there is a need for a UK wide scheme.”

Influencing design choice

Discussing the issue of influencing design choices across the packaging industry, Robbie said that the industry should also look at how existing legislation can then interact with the EPR regime “to potentially modulate a fee based on design criteria and guidance. There will be many regimes, and not just packaging, but things like mattresses and textiles, carpets and furniture where EPR could be introduced, but there won’t be design requirements.

“The reality is the amount of legislation that you get bogged down in if you’re looking at design criteria for all of these things, and although we welcome it for electrical goods and for some others where there are problems with chemicals for example, designers just won’t want to be restricted by all of this design legislation. Therefore EPR in that instance must address design where appropriate.”

Utilising existing infrastructure

Throughout his talk, Robbie spoke about the importance of utilising the existing infrastructure that is already out there for a new EPR regime, especially in regards to WEEE regulations, but that it’s important not to be constrained by it. He said: “The WEEE regulations are a fantastic example as it doesn’t arrive at local authority sites in the same way that it used to, and so we need a system that is flexible enough and broad enough to take into account all of the different types of ways that waste can arise.”

In addition, he also warned against the imbalances of the existing systems, added that although within the packaging regime the producers and schemes must comply with the law by obtaining enough evidence for recycling, “the recyclers themselves have nothing on the line. Unless there is an economic imperative, that negotiating position for both parties is heavily weighted in one direction.”

The responsibilities of producers

Touching on the need for the industry to directly link the contributions that producers make to the tangible outcomes, Robbie argued that we need to be looking at what innovation has occurred because producers have put more money into this. He said this means considering what infrastructure has been created because of the money that producers have put into it, and the education that has been transferred to the population “so that we all are better aware of what we can recycle and where”.

As a result, Robbie believes there is a need for “individual producer responsibility”, especially as Circular Economy models become more widespread and producers take more of an interest in the waste they generate and where it goes.

Harnessing initiatives across the UK

Robbie finally commented on the need to work together towards a greater result. "If we look across to batteries, a good example is what we have done with WRAP in making collection points more available on the Recycle Now website, and encouraging the other schemes to do the same thing. All battery points sit within one central location, the issue is the inconsistency between collections, and the opportunity is to review the consistency and try to harness things across the UK as a whole.

If you would like to discuss how any of these issues could affect your compliance obligations, please contact us.

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