Wales launches street binned and littered packaging EPR payments consultation

Wales takes steps towards increasing the amount producers pay for street-binned and littered packaging.  

During the initial consultation process for Extended Producer Responsibility for Packaging (pEPR), it was proposed that obligated producers – in addition to the waste management/disposal fees subsidising household collections – should also cover the costs of littered and publicly binned packaging waste too. In 2022 it was announced that England and Northern Ireland would not introduce these additional costs, but Wales and Scotland would keep the policy under consideration.

On 30 January, the Welsh government released a consultation “to gather views on the way in which the pEPR scheme should be developed to account for ‘on the go’ packaging waste which is placed in public bins or littered in Wales”.

The publication states that former consultation responses showed broad support for the principle of ‘on the go’ and litter payments and, given the majority of the cost burden for collections and clear-up currently sits with local authorities, introducing them is aligned with the ‘polluter pays principle’. Essentially, the consultation lays out that a producer’s responsibility for the full net cost of their packaging does not stop at household recycling collections.

Currently, the waste management fees producers are charged under pEPR reimburse local authorities for the collection and sorting of packaging waste from the kerbside. However, the consultation proposes that in Wales these costs could now be extended to reimburse activities such as the provision of bins, anti-litter campaigns and the operational costs of collecting ground litter.

Historically divisive

The case of litter and street bin payments under pEPR has proven historically to be divisive – some feel that the logical conclusion of the polluter pays principle is that businesses should pay for the entirety of their product wherever it becomes waste, regardless of whether it is disposed of correctly or not. Others, however, feel that littering is a societal issue and not the responsibility of industry to fund the remediation of it.

Whether or not Wales (and potentially Scotland) decide to go ahead with these additional costs to producers, the effects of further regulatory misalignment on other aspects of compliance should be carefully considered - particularly concerning packaging data collection and submission.

Obligated producers are already contending with the now mandatory  and the significant additional data burden that entails, plus imminent data requirements needed to comply with the UK Deposit Return Scheme next year – made more complex if Wales include glass in a separate scheme.