EPR Regulations 2023


As the Food and Drink industry comes together to highlight flaws in the government’s proposed new EPR regulations, Paul Freeston, President of the Food & Drink Federation (FDF) and CEO & Chair of apetito UK and North America, has warned that the ultimate price will be paid by the consumer at a time when they can ill afford it.

The UK government plans to introduce new regulations for “extended producer responsibility” (EPR), to tackle the growing problem of packaging waste. These regulations aim to shift the waste and recycling costs of packaging from local authorities to the businesses that produce it - a principle that industry is supportive of.

However, Freeston says that not only are there significant concerns about how the government plans to implement EPR, which ignores advice from industry and other best-practice EPR schemes on the continent, but there are some unjustifiable omissions.

He maintains it will penalise recycling front-runners, businesses who have already invested in closed-loop recycling systems, reducing the need for new materials and minimising waste:

“We fully support the principles of EPR – responsible use of plastic is the right way to do business.

“However, government has announced that it will simply not consider closed-loop systems for at least a year after EPR commences – failing to account for the fact that the most responsible businesses have invested significantly in future-looking systems that improve rates of re-use and recycling.

“And even when they do come to consider closed-loop, they have suggested that they will only make allowances for materials that are not “commonly collected” – even if the closed-loop system (such as our own) generates far better results.

“It is patently unfair that these businesses are to be taxed as if they simply had done nothing and the industry is shocked to see there is no allowance for those who are taking plastic out of the system. Everyone will be subject to these new taxes, which means good sustainable businesses will be paying twice!

“And there’s only one possible outcome - which is increased costs to the consumer. One can suggest - that as a business, if we were to charge customers for services that we were not providing, this would be deemed illegal. It is obviously unjust and improper and a direct disincentive for companies to innovate and develop environmental solutions that support government objectives.”

Freeston says it’s an irony that regulations which are designed to encourage businesses to create products that are easier to recycle and to increase the use of recycled content in their products, will do the opposite to businesses who are currently doing the ‘right thing’.

“As things stand EPR is looking like just another tax and a missed opportunity for Government to address packaging waste”.

Freeston’s own business, apetito which incorporates Wiltshire Farm Foods, is an illustrative example being market-leader in home-delivered ready meals to the elderly.

Since 2021, Wiltshire Farm Foods has been collecting the plastic trays (with up to 80% recycled material) from the homes of its customers and reusing the material to make new trays. This ‘industrial scale’ closed-loop system is believed to be a world-first and an exemplar approach to packaging recycling and re-use.

Freeston concludes:

“It’s important that the government recognises the value of closed loop packaging initiatives and works to support and encourage businesses that operate in this way. Our system not only addresses the lack of investment in UK recycling infrastructure, we achieve both better collection rates than those of UK household recycling, and better recycling rates – we guarantee that 100% of trays collected will be turned into new trays right here in the UK.

“We welcome government packaging reform to combat the packaging waste challenge, but in its proposed current format, it will directly penalise those investing in driving environmental benefit and do so at a greater cost to the average consumers shopping basket. We implore Government to change its approach”

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