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  • Abhay Bhagwat

Extended Producer Responsibility: Looking ahead at 2023

Updated: Sep 14, 2022

More than 10 million tonnes of packaging waste is produced every year in the UK. As we have seen in our other blogs (Don't rely on Recycle. Reduce Blog), most of this waste contributes to pollution, and all of it contributes to costs that the Government has to cover, which often means taxes. But how does a government levy targeted taxes so that the "polluter pays"? And pays in proportion to the environmental impact of their products?

Extended Producer Responsibility (EPR) arose from research by Thomas Lindhqvist in 1990 at Lund University. As he tried to understand how waste management systems were leading to policies for cleaner production, he birthed the notion that manufacturers in Sweden could be accountable for the environmental impact of their products to the Swedish Ministry of the Environment.

Since then, the concept has developed, and it wasn't long before Germany introduced its first EPR policies. Some 30 years later, the UK is now getting ready to introduce its own EPR policies in 2023.

A well-planned EPR scheme can reduce the burden on public budgets, incentivise effective collection and promote better end-of-life management of wastes. EPR schemes strengthen the plastic waste value chain and try to bring transparency and accountability to the system. It also creates a level playing field. But perhaps the most significant effect they have is incentivising upstream packaging innovation and promoting ideas like eco-design.

Surveys of the British public have shown a desire for improvements in these areas, and many small businesses will be happy to participate in a fairly planned and implemented scheme. The Government has worked to ensure that those categorised as "obligated producers" will be capable of managing the burdens that are placed on them.

The proposal is that there will be six categories of "obligated producers", and some situations will be more complex than others. . Each category will have different kinds of obligations. The six categories will be:

Category of Obligated Producer



Brand Owners

Businesses who either put goods into packaging, or have goods put into packaging, and place those goods on the UK market under their brand name.



Businesses who are responsible for the import of filled packaging into the UK for sale. Where the importer is not based in the UK, it will be the first UK based owner of the packaging who takes this obligation.



Businesses who sell unfilled packaging to producers who are below the de minimis threshold take on the obligation for that packaging. This may be wholesalers/distributors, importers or any other business who sells directly to unobligated producers.


Online Marketplaces

Businesses based in the UK who operate a website, or any other means by which information is made available over the internet, through which persons based outside the UK, other than the operator, are able to offer filled packaging for sale in the UK (whether or not the operator also does so).



Businesses in the UK who sell any filled packaging to the end user. This includes all types of packaging, so could be, for example, supermarkets in relation to primary packaging, or manufacturers in relation to secondary or transit packaging. .


Service Providers

Businesses who supply reusable packaging to a user of that packaging where the supply is made by hiring out or lending the packaging

Individual businesses may take on more than one obligation. For example, if a business is both the brand owner and the seller of a packaged product, it would take on obligations as both a Brand Owner (A) and a Seller (E). The 213-page government document: Extended Producer Responsibility for Packaging Consultation Document 24 March 2021 provides many further details. The document is available online here.

With more obligations being placed on producers to take responsibility for the waste their packaging creates, there will be more incentive than ever to reduce the amount of material used in their packs from the outset.

Packaging for the Future is a specialist in this area, having already saved over 100,000 tonnes of plastic waste alone. If you'd like to see how we can help you cut down on your use of material while maintaining or enhancing design, be in touch for a free consultation.

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