UK Packaging Reforms 2020 – 2023


UK Packaging Reforms Review

As a packaged goods business, it is more important than ever to keep informed about new regulations. Right now, there are several UK and European legislation changes being planned so we are sharing highlights of the new packaging reforms in the UK to keep you up to date and help you avoid unnecessarily packaging penalties.

As the UK government implements their 25-year environmental plan, and Waste and Resource Strategy, we take a look at these ambitious moves which should position the UK as a world leader in the circular economy. However, to achieve this, significant changes are required by packaged product businesses.

In this article, we summarise the changes being debated in the UK and highlight the watch-outs for branded product businesses so that you can prepare your business for the changes ahead.


Extended Producer Responsibility (EPR)

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

The UK recycling rates are stagnating at about 45% and as brand owners, your business is only contributing to around 10% of packaging waste management. The remaining 90% is covered by the taxpayer. As a result, the government plans to change this so that, as a brand, you are more financially incentivised to create sustainable packaging. It is the most complex of the reforms, here are five key proposals being debated and the important watch-outs for you:


1. The Polluter Pays (Full Net Cost Recovery)

  • As producers, you will soon pay the full cost of managing packaging waste: from bin collection and recycling to anti-litter campaigns. 

What does this mean? There is going to be an increase in the ‘cost of doing business’ linked to the weight of your packaging and volume of sales. Lightweighting and/or re-designing your packs could help you mitigate some of these charges.


2. Better Packaging Design 

There are two possible plans, both designed to financially incentivise you to design your packs for easy recycling:

 Option 1: An upfront fee for all non-recyclable or difficult to recycle packaging.

Option 2:Deposits on all packaging with some or all refunded where a closed-loop system or recycling is proven.

What does this mean? Packaging will need to be designed for recyclability or re-use. Simply put, to keep costs low, you should select commonly collected & recycled materials and avoid packaging that’s tough to recycle i.e. laminates or carbon black plastic


3. Responsible Party 

Currently, you’re an obligated packaging producer if you:

  • handled 50 tonnes of packaging materials or packaging in the previous calendar year
  • have a turnover of more than £2 million a year (based on the last financial year’s accounts)

This is also going to change, and soon, the full packaging waste management cost in the UK will be allocated either by:

  1. A Single Point of Compliance: The threshold remains but the full cost of packaging waste management will sit either with:
    • The Producer (Brand) or
    • The Seller (Retailer)
  2. The removal of the Compliance Threshold: All producers, no matter your size, will be obliged to pay for the packaging waste management you’re putting into the market.

What does this mean? There will be increased fees and increased pressure by retailers for you to make packaging more sustainable. However, care must be taken to ensure packs are fit for purpose after any re-development.

4. Consistent Collections

To increase clarity for consumers about what can be recycled, a core set of waste packaging materials will be collected across all local authorities in the UK.

What does this mean? In 2023, specific materials will be collected across all local authorities. If your packaging materials aren’t on that list, it may become more challenging to claim ‘recyclable’ and a specification change might be advised.


5. Helping Consumers Recycle

Again, for end-user clarity, consistent labelling is important and effective in getting the right materials in the correct bins and increasing recycling in the UK and so mandatory labels, on-pack, will identify packaging as ‘Recyclable’ or ‘Not-Recyclable’. While we all appreciate recycling is not this simple, consumers need clarity so a simple message is preferred.

What does this mean? 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. Being aware of the definitions will be key to making sure you’re on the right side of these regulations.


How do these proposals affect your branded product business?

The EPR has many impacts to consider for you including a direct cost to business, new schemes to comply with and mandatory label changes. Time and resources will be required to mitigate costs and comply with the new packaging reforms. Re-designing and re-specifying packaging may be an important part of your branded product business in the coming months and years. Circle Packaging can help you so do contact us with sustainability advice and technical support.


Consultation – Deposit Return Scheme (DRS)

Defra Consultation on DRS – Feb 2019

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

How it works:

  1. Consumers pay deposits at the point of purchase.
  2. Deposit refunded upon bottle return at DRS point.

How does this scheme affect your branded product business?

As a drinks producer, you 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:

The new scheme will be implemented in 2023.

Consultation – Plastic Packaging Tax

A new tax on virgin plastic packaging.

The proposed changes:

  • A £200/Tonne 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 of doing business: either a levy applied for not using enough recycled plastic or a higher cost to your packaging for including more recycled plastic. There is likely going to be a struggle to secure recycled material for your packaging too. 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 2021 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 packaging advice and technical support to implement your sustainable packaging so call us for an initial assessment and help us to help you be a better purpose-led business.


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