MP fears EPR will disincentivise closed-loop investments

On 3 May, Labour’s Dame Nia Griffith MP raised concerns in Parliament over Extended Producer Responsibility (EPR) for Packaging Waste, and potential ‘unintended consequences’ that will disincentivise investments into closed-loop recycling. 

Rebecca Pow 3 May 2023
The company have apparently written to Rebecca Pow, the Parliamentary Under-Secretary of State for Defra
The MP for Llanelli, Wales, raised a possible case study in which Wiltshire Farm Foods – a manufacturer and delivery service for ready-made meals in plastic trays that are covered with a thin polythene film – will be incorrectly taxed.

The company and Dame Griffith fear that despite investments in a closed-loop system, the company will be taxed as if the trays went into the waste system.

The company has a regular customer base and collects old, used trays while making fresh deliveries. The necessary nutritional information is put on the plastic film, which is the only thing the customer disposes of. Wiltshire Farm Foods claims to leave behind 97 per cent less packaging by weight than other ready-meal brands due to this system.

In 2021 the company also invested in a new packaging recycling initiative in its Durham factory – the ‘boomerang project’. It takes the used plastic CPET meal trays and recycles them into new trays containing up to 85 per cent recycled tray material.

The company have apparently written to Rebecca Pow, the Parliamentary Under-Secretary of State for Defra, and was told that ‘the trays will be equated with household waste and cannot be considered as any form of exception or betterment, because technically they could have gone into householders’ recycling waste bags or boxes’.

Dame Griffith also raised that the Food and Drink Federation has stated concerns that the proposed system will fail to achieve improvements in recycling rates. It advises that Defra should look at international best practice from the most successful schemes around the world to inform its plans.

Dame Griffith added: “The problem is that firms get no credit for trying to maximise the collection and recycling of their packaging. That is a massive disincentive to make any such investment, whereas they could help to improve our plastic packaging recycling rates, as well as the efficiency and quality of that recycling; otherwise, there is no reason for them to do so.”

Pow responded that EPR aims to incentivise producers to recycle packaging that is reused multiple times, such as milk bottles, and allow businesses to collect and recycle their packaging – where local authorities are not already required to collect those items for recycling.

However, EPR will not allow for offsetting of packaging where it is collected by more than 75 per cent of local authorities, except where it is part of a reuse system. She states that this is primarily because Defra will take steps, through consistency measures, to place requirements on local authorities to collect, for recycling, at least the common set of materials: plastic, wood, aluminium, steel, paper and card, and glass.

The response to the consultation on consistency in recycling in England is expected to come as the local elections draw to a close.

Pow concludes: “If we incentivise producers to collect their own packaging, which we are also requiring local authorities to collect, that will reduce the efficiency of kerbside collections overall and therefore increase costs for producers. It will undermine that system, which will be a cornerstone of the whole triage.”