ACR+

By Dr Chris Sherrington, Mark Hilton, Ayesha Bapasola, Olly Jamieson, Jade Kelly.

Eunomia Research & Consulting Ltd (Eunomia) was commissioned by the Welsh Government to identify options, in line with Extended Producer Responsibility(EPR) principles, to tackle a number of issues associated with key food and drink (F&D) packaging. This work will feed into the development of a wider EPR approach in Wales, in line with the revisions to Article 8(a) of the Waste Framework Directive. Accordingly, such approaches should seek to achieve full net cost recovery, but dropping to 80% in some circumstances. Such a rebalancing of costs away from citizens/taxpayers towards consumers/producers would be entirely in line with the Welsh Government’s Programme for Wales, Taking Wales Forward, with its emphasis on a stronger and fairer economy.

In addition, the Welsh Government has sought further understanding of the potential scope for an EPR approach that:

reduces the amount of waste and increases reuse, repair, remanufacture and recycling, to the maximum practicable extent.

This is an ambitious objective, recognising a need to drive improvements and innovation in Wales that have real potential, and yet, are far from being fully realised in EPR schemes across the globe.

Indeed, in terms of waste prevention, as far as the target food and drink packaging types are concerned, it is far from clear that EPR on its own can deliver this objective (with the exception of stimulating lightweight). While modulated fees can incentivise design for recyclability, and the incorporation of recycled content, to bring about significant waste prevention, in terms of a reduction in the number of items consumed, other measures are required, such as taxes or charges.

It's worth noting that the Welsh Government is not, in this project, looking to explore comprehensive EPR across all packaging types. The study does not, therefore, consider in detail how EPR for packaging might be reformed in Wales. Instead, the focus is on identifying specific measures that can be applied to particular types of packaging, which can bring about waste prevention, litter prevention, and/or increase recycling, in ways that are consistent with EPR principles.

It’s also important to acknowledge the wider context, of ongoing discussions regarding shortcomings in the way in which producer responsibility for packaging is currently discharged in the UK, and the likelihood of, at least, a modification, if not a more wholesale revision, of the system of producer responsibility in the relatively near term. Indeed, any requirement to approximate to the text of the Waste Framework Directive’s Article 8a, recognising that the Packaging and Packaging Waste Directive remains a ‘Single Market’ Directive, would require a fundamental shift in the distribution of costs under the UK’s scheme.

In this context, it is important to understand that while there is a jointly agreed approach to the Packaging Regulations across the four countries in the UK, the Welsh Government does have powers to have a separate approach, as long as the minimum requirements of the Packaging Directive are met.