Government launches consultation on EPR, DRS, consistency and recycled content tax

18 FEBRUARY 2019

The government's long awaited consultations aimed primarily at packaging waste have now been published, all on a 12 week response time.

Extended producer responsibility. This is the first of stab at considering a range of options to replace the current PRN system for packaging for the whole UK with a further consultation likely in early 2020. The changes are driven by the EU Circular Economy Package which the UK is signed up to regardless of the Brexit outcome and which requires producers to pay the full net cost of collection, recycling and disposal of household (and similar) packaging waste as well as the cost of litter clear up and public communications. This is likely to see the annual cost to producers rise from the PRN system average of around £70m to around ten times that amount. Four options are considered including a move towards a single body management system and a split of household and Commercial/industrial waste targets and management. The consultation also considers targets from 2021 onwards, mandatory labelling and a range of technical changes such as a tightening of export controls and the application of costs to all producers. At 125 pages (plus 57 pages for the Impact assessment) and with 92 questions, this is not for the faint hearted.

Deposit return scheme (DRS). This puts forward two options for the implementation of a system in England that would see consumers paying a deposit on the purchase of certain beverage containers that would be reimbursed by retailers on the return of the container. For those with long memories, this is similar to the old Corona bottle system and reflects the recent consultation by Scotland on a similar system. 

Consistency. With the proliferation of different Council recycling collection schemes, this is a consultation on proposals to harmonise the types of recyclables that each Council collects in England. It also looks at whether businesses in England should be required to present recyclables for collection separate to other waste as already happens in Scotland and is planned for Wales.

Recycled content tax. This is a consultation issued by the Treasury on the implementation of the 30% recycled content in single use plastic mentioned in the October budget and due to start in 2022. With complications such as the definition of single use plastics and imports, this will be extremely complex.

All four of these consultations not only have to be considered in isolation, but also in the context of each other and other policy and legislation areas such as the EU's Single Use Plastics Directive and the UK Plastic Pact.

Having originally stated an 8 week response intent, the government has bowed to widespread concern and extended the response time to 12 weeks. All the consultations close on 13 May other than the recycled content one that closes on 12 May.