Extended Producer Responsibility for Packaging

Extended Producer Responsibility (EPR) is a key policy mechanism used by countries worldwide and provides guidance for the transition towards a greener economy. It encourages businesses to reduce the amount of packaging they use, reduce the amount of packaging that ends up in landfill, and increase the amount of packaging waste that’s recycled and recovered.

Under the Green Deal, EU Member States must establish producer responsibility schemes for all packaging by 2024.

Nations with EPR schemes in place are taking different approaches. Some countries, like Germany, have no minimum threshold for the volume of packaging you place on the market, including online sales (i.e. you need to pay the fee even if you place a small amount on the market). Other countries, such as Spain, have simplified declaration requirements for small amounts of material placed on the market.

Eco-modulation is a concept increasingly implemented by governments across the world.

The principle of eco-modulation is to financially incentivise businesses to design packaging that is easier to recycle. Fees per tonne of material placed on the market are applied, and materials that are harder to recycle have higher fees.

Countries including Belgium, Italy and Spain already have eco-modulation in place, as do all Scandinavian countries.

There are different categories of producer depending on what the national policy sets out. Things like whether you sell a product online or in stores, whether you are a brand owner vs a distributor, and whether a piece of packaging is actually packaging. These are areas that not all countries align on. For example, coffee capsules can be considered crucial to product delivery, but they are also packaging.

However, we expect some things to change to benefit the environment rather than the producer over time.

Bio-degradable, bio-based and compostable plastic packaging is not considered recyclable in some markets (France and the UK) and will incur higher fees as a result. In other countries, like Italy, they are treated preferentially.

Upcoming changes will require additional data collection requirements, with increased reporting obligations. Reports will become more complex and require aggregates for sales made in each devolved administration.

Some schemes will offer discounts on EPR fees if packaging for basics, such as clear recycling labelling, is in place, and others reward parallel behaviour change drivers such as marketing campaigns that encourage less litter or more recycling. An example of his is the Citeo scheme in France.

The fast-changing policy landscape, specific to EPR fees, means that businesses must act swiftly to ensure they are reporting correctly and registered appropriately for relevant country schemes to avoid fines.

Many of our clients have carried out cost analysis on key parts of their packaging portfolio and come to us for help to map this against key environmental and social impacts. We help them define which material or pack format they should use.

We suggest you start with a holistic Packaging Strategy because policy costs are just one of many factors you need to be taken into consideration to truly future-proof your business.