Packaging Reforms 2020


Packaging Reforms Review

Details of new packaging reforms are about to land in the UK as the government implement their 25-year environmental plan, and Waste and Resource Strategy. These ambitious plans position the UK as a world leader in recycling, but significant changes are required by branded product businesses to achieve so much.

This article summarises the planned changes and highlights the watch-outs for branded product businesses so that you can prepare for the changes ahead.


Four Consultation Review

Four key packaging consultations were published in 2018 to implement the new packaging reforms. These will be finalised in 2020 and come into force 2022/ 2023.

This is a short breakdown of how they will work and what they will mean to branded product businesses.

Consultation 1 – Consistent Collections

All UK local authorities will collect the same kinds of packaging waste. This will make recycling easier for consumers.

How does this affect your branded product business?

More collections of set materials will increase collection quality and quantity. This means greater availability of recycled material for use in new packaging.

Next Steps:

A consultation containing detailed proposals for this packaging reform will be published early 2020. Changes come into effect in 2023.


Consultation 2 – Extended Producer Responsibility (EPR)

EPR Scheme – Our Waste, Our Resources: A Strategy for England

The current Packaging Recovery Note (PRN) system requires reform. This is because UK recycling rates are stagnating and producers only contribute 7% to managing packaging waste. The government wants this to change.

In the most complex of the reforms, these five key proposals directly affect branded product businesses:


1. Full Net Cost Recovery Paid by Producers 

Producers will pay the full cost of managing packaging waste from bin collection and recycling through to anti-litter campaigns. 

What this means: There will be a big cost increase to branded product businesses. Lightweighting or re-designing your pack may mitigate some of these charges.


2. Better Packaging Design 

Producers should design packs for easy recycling. Two options being considered to achieve this:

Option 1: Producers will pay an upfront fee for non-recyclable or difficult to recycle packaging.

Option 2: Deposits to be paid on packaging with some or all refundable where closed-loop or recycling is proved.

What this means: Packaging should be designed for recyclability to avoid penalties e.g. select commonly collected & recycled materials and avoid downgrading packaging i.e. using black plastic


3. Responsible Party Changes

Who pays for packaging waste management in the UK will change to encourage the uptake of ‘Better Packaging Design’. Two options being considered to implement this:

Option 1: Single Point of Compliance. The full cost for packaging waste to sit with either Producer or Seller (or importer) – this will maximise the impact of ‘Better Packaging Design’ incentives

Option 2: Remove Threshold of Compliance. All producers, big and small, will be obligated – this will encourage ‘Better Packagnig Design’ for all businesses.

What this means: With increased fees, branded product businesses should focus on packaging weight reduction or re-design. Care must be taken to ensure packs are fit for purpose after any re-development.


4. Consistent Collections

The same packaging materials collected for recycling across all UK councils.

What this means: The list of chosen materials being collected will define what will be considered ‘recyclable’. If your packaging materials aren’t on that list, it may become more challenging to claim ‘recyclable’ and a specification change might be advised.

OPRL Binary Labelling System – Launched Jan 2020


5. Helping Consumers Recycle

Mandatory labels, back of pack, will identify packaging as ‘Recyclable’ or ‘Not-Recyclable’.

Recycling is not this black and white but consumers are confused so a simple message is preferred.

What this means: The definition for ‘Recyclable’ chosen for this packaging regulation could mean your packaging will not be classified as recyclable even if you think it is.


How do these proposals affect your branded product business?

The EPR has many impacts to consider including a direct cost to business, new schemes to comply with and mandatory label changes. Time and resource will be required to mitigate costs and comply with the new packaging reforms. Re-designing and re-specifying packaging may be essential for your branded product business under these new terms.

Next Steps:

DEFRA plan to publish more details in 2020 and for Extended Producer Responsibility to come into effect in 2023.


Consultation 3 – Deposit Return Scheme (DRS)

An introduction of single-use-bottle collection points to encourage more recycling.

How it works:

  • Consumers pay deposit at point of purchase.
  • Deposit refunded upon bottle return at DRS point.

How does this scheme affect your branded product business?

Drinks producers will need to join and meet targets set by the DRS scheme. It’s not clear yet if this will be for on-the-go packs only or bottles of larger sizes.

Next Steps:

A consultation on the scope and model of the scheme is due in 2020 and will be implemented in 2023.

Defra Consultation on DRS – Feb 2019

Consultation 4 – Plastic Packaging Tax

A new tax on virgin plastic packaging.

The proposed changes:

  • A tax on plastic packaging with less than 30% recycled content.

(this includes bio-based, compostable, biodegradable and oxo-degradable plastic packaging).

  • The planned rate will make recycled content cost-competitive vs virgin

How does this tax affect your branded product business?

There will be an additional cost to business. Either there will be a levy applied for not using enough recycled plastic or a higher cost to your packaging for including more recycled plastic. In addition, there probably won’t be enough recycled material available for all businesses to avoid this new tax. Securing supply should be a priority for branded product businesses wanting to move. A further issue is the availability of recycled polypropylene (PP), used in many pots, tubs & trays. Businesses using this material may want to look at alternative packaging options.

Next Steps:

Draft legislation is due in 2020 and the plastic tax is coming into force from April 2022.


Get Ready for Packaging Reforms

These new packaging reforms will affect your branded product business but there are ways to prepare for the changes. These include designing for recyclability. lightweighting and including recycled content in your pack. Having a game plan to meet these changes will be highly valuable to avoid the planned new charges.

Circle Packaging provides freelance packaging support to implement sustainable packaging to branded businesses. All changes will be fit for your brand, supply chain and most importantly, your consumer.

Circle Packaging offers a no-obligation assessment of your packaging needs for those wanting to know more.

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