SUEZ outlines key principles for effective UK EPR regime

Waste management company SUEZ recycling and recovery UK has released a report detailing 10 fundamental principles for an effective extended producer responsibility (EPR) regime for the UK, including incentivising sustainable product design and providing a clear and simple system for both producers and consumers.

The document, entitled ‘Un-packaging Extended Producer Responsibility’, was released at RWM 2018 on 12 September at the NEC in Birmingham and provides guidance as to how a fair and equitable producer responsibility regime could be most effectively implemented in the UK – based on the outcomes of workshops held with a wide range of stakeholders spanning the economic value chain.

Over the past three months, SUEZ has conducted more than 25 workshops with various groups and organisations, seeking feedback on a range of policy interventions proposed by the company in its manifesto for the future of resources and waste in England, which was published in late May 2018.

EPR regimes see the cost of the management of products at the end of their life incorporated into the price of a product. This incentivises producers of obligated products to design for sustainability in order to reduce the cost of the management of the product at its end of life, thus passing on fewer costs to the consumer.

Given that the UK has indicated that it will sign up to the EU’s Circular Economy Package, the UK has committed to implementing an EPR regime that recovers at least 80 per cent of the full net costs associated with dealing with obligated products at their end of life, though SUEZ argues that implementing a 100 per cent full cost recovery regime would help cover the cost of dealing with litter and residual waste management.

The fundamental principles that SUEZ believes will be necessary to create a world-leading producer responsibility system in the UK are as follows:

1. More sustainable design. EPR should encourage producers and designers to design products for recycling, repair or reuse and make more use of secondary materials, while any environmental burden designed into a product should be reflected in its cost.
2. Enhanced brand equity. Brands should be able to differentiate from their competitors on the basis of environmental performance and should be rewarded for progressing this area.
3. A level playing field. EPR obligations should apply to all companies operating in the UK market (not just England) and to all materials and products placed on the market. These products should meet minimum sustainable design standards in the UK.
4. Informed, empowered consumers. Through EPR, consumers should be empowered to make more sustainable choices through national communications campaigns that retain a sufficient flexibility as to be locally relevant.
5. A competitive marketplace. A good EPR system should encourage competition at all levels of the value chain.
6. Innovation. A well-designed EPR regime should encourage materials, systems and product design innovations, while also taking into account the transition period and potential disruptive impacts of these changes.
7. Simplicity for all. New processes for placing materials on the market, recovering them from the consumer at their end of life and reprocessing them should work within existing systems where possible, while processes should be simplified where change is necessary.
8. Minimal consumer cost. As consumers will pay for an EPR regime through the cost of products they buy, schemes must work to deliver the best outcomes for the lowest cost.
9. A system free from crime. To avoid criminality, systems should be designed with clear standards for operators, appropriate barriers to entry and robust processes for collecting and auditing data.
10. Rewards and penalties. Producers that meet environmental goals should be rewarded while those that do not should be penalised. The costs of failure should be borne by obligated companies that do not meet their responsibilities.

Commenting on the release of the report, Stuart Hayward-Higham, Technical Development Director at SUEZ, said: “The principles we present for a world-leading producer responsibility scheme in this body of work are the culmination of hundreds of conversations between SUEZ and various actors within the economic value chain over the past couple of years. We believe they therefore provide robust and useful guidance to policy-makers considering this vital topic and we would like to thank all of the people who have helped us to form these views.

“Designing an extended producer responsibility scheme which is efficient in both cost and delivery, and which therefore minimises passed-on costs to consumers, is essential. We also believe that consumers should be given simple, on-product, information so they can make informed choices about the sustainability of the things they purchase.

“Furthermore, we believe that the design of EPR systems should ensure they can expand and be scaled as necessary, so we do not end up with multiple repeated schemes. Finally, ensuring that robust evidence can be easily gathered, and used to prevent fraud, is vital for the success of an EPR regime – which should also make successes and failures transparent and allow society to reward the best performers.”

You can view the report, ‘Un-packaging Extended Producer Responsibility’, in full on the SUEZ website.