The government has listened on EPR, but has it learned?
FWD Chairman Dawood Pervez poses the question following DEFRA’s decision to postpone proposed EPR legislation
July’s announcement by DEFRA that it was postponing the proposed EPR legislation until mid-2024 to allow for further consultation was very welcome if not something of a surprise to many who understood the government was looking to stand firm and lay down the legislation prior to summer recess.
It’s fair to say that our industry has welcomed the principles of EPR. As I write, July has seen three world records for the hottest days the globe has ever seen, compounded by Europe turning into an inferno of wildfires. It is reported that beyond doubt, these temperatures are due to human interference.
There is no question that a collaborative approach is needed across our industry, the supply chain, and the government in order to combat climate change. However, it is imperative that this legislation delivers the aims of EPR without a stream of unintended consequences that place more cost on the consumer. It must be clearly thought through so it is workable and reflects a deep understanding of the complexities while presenting solutions.
And of course, government needs to limit those costs that ultimately will have to be paid for by the consumer at a time when household budgets are already stretched to the max. One could argue that while the government’s aims were laudable, it simply wasn’t ready to unroll the legislation in a way that was going to drive successful conclusions.
Are there lessons to be learned from other countries…?
Definitely, yes. The German waste disposal system combines with other businesses and influencers to recycle around 63% of the country’s plastic waste to use in different mediums and forms. This includes making use of recycled plastic as an alternative to gas and petrol.
Here in the UK, it’s estimated that 44.2% of plastic packaging was recycled in 2021 but this included energy recovery from incineration and plastic waste exports, so it is believed that the real rate is closer to 38%. From that 38% collected, it is believed that only around 48% is actually recycled. This must change.
We must use the postponement time wisely…
We now have a window of opportunity with this renewed consultation period to reinforce the crucial points and EPR direction, where we believe change is important.
There are many elements for consideration and a need for clear definitions around ownership of waste and packaging. Are wholesalers defined as manufacturers when it comes to own-label ranges where waste is ultimately going to kerbside? How is that measured? Where does tertiary shipping and transport packaging sit that comes into depots and retailers and will it change the whole approach to circular recycling systems? How does it take account of complexities around cash and carry versus delivered versus collect services that all form different components of a wholesale business?
We must use this time to regroup, encourage and urge DEFRA to understand more about our sector and the consequences of their proposed approach.
The role of the FWD is vital in consulting with DEFRA and working together for the future of our sector across extended produce responsibility. Whether this is to ensure the right definitions are in place, consider best practice, look at the likely cost implications or how this will get passed to the consumer, we cannot sit back and think we have time to waste. Now is the time for us to work together to achieve the right results for all stakeholders.Dawood Pervez extended producer responsibility FWD Government legislation packaging recycling