The newly published extended producer responsibility (EPR) fees for packaging have left many in the industry baffled. Has Defra really created a system that risks encouraging brands and retailers to make packaging decisions driven primarily by cost per tonne, punishing British manufacturers in the process? Unfortunately, yes.
After being told the December illustrative fees were accurate enough for budgeting, the drastic fee changes cast serious doubt on the scheme’s purpose. EPR is meant to drive better recyclability and environmental outcomes. Instead, it looks likely to promote more plastic and cheaper imports, financially penalising those that have been transitioning towards renewable, sustainably sourced, and highly recyclable materials, and undermining the government’s commitment to a circular economy.
Plastic alternatives
Fibre-based composites (FBCs) have been a crucial part of innovation to provide an alternative to plastic packaging, combining paperboard with coatings (often plastic or bio-based) to enable similar properties to plastic packs. These are particularly relevant across food packaging, which demands grease resistance, chilled display and heating. FBCs are vital in balancing functionality with sustainability, and have the potential to replace much of the fossil-based plastic packaging on the market.
Yet, the new fee structure penalises investment in these formats. Plastic sees a 13% base fee decrease, while FBCs become the most expensive option. Perhaps Defra will argue the fee accurately represents the cost of recycling today. However, in doing so, it presents an EPR scheme in stasis – designed on local authorities’ current estimations of cost, without recognising that they do not have data on the wide variety of FBC formats, nor that plastic is much lighter than paperboard. Products with just over 5% plastic content will be charged almost 2.5 times more than those just under (and therefore in the paper and board category), making the significant change in fees even more concerning.
Cost or sustainability?
With price in mind, it’s almost certain we will see producers forced to choose between cost and sustainability. They may turn to fully plastic packaging or switch to low-quality fibre products sourced from markets that do not offer full traceability, quality assurance, or adequate food safety certifications. Instead of incentivising sustainably sourced choices, the system encourages a race to the bottom.
We need a smarter EPR system – one that considers the full carbon impact of packaging and ensures the funds raised are reinvested into recycling infrastructure. As it stands, EPR fails on both fronts. It overlooks the role fibre-based products can play in replacing fossil-based materials and lacks a mechanism to ringfence funds for system improvements. This prompts a critical question: is packaging policy being shaped more by today’s ageing waste management infrastructure than by environmental priorities?
Any EPR scheme takes time to settle, and it should be effective in taking hard-to-recycle materials out of the market, but it should not punish British industry from the outset for using recyclable FBC formats or push businesses away from renewable material choices. If this pricing model remains, we risk undoing years of material and sourcing improvements, and sending a message that innovation isn’t worth it.
The Alliance for Fibre-Based Packaging’s members alone employ 210,000 people across the UK and generate £24bn in turnover. Alongside many other manufacturers and producers, we contribute to economic growth and to the UK’s net zero transition. We agree that producers should pay – but not at the cost of more plastic, less innovation and less homegrown industry.
Talia Goldman is ESG director at Colpac and co-chair & co-founder of the Alliance for Fibre-Based Packaging
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