As the deadline for the UK government’s consultation on reforms to Extended Producer Responsibility (EPR) for packaging looms on October 9th, Valpak, the country’s largest environmental compliance scheme, is urging textile and clothing brands, packaging producers and retailers to make their voices heard.

Issues still to be finalised include plans for deposit return scheme (DRS) packaging and whether responsible producers should bear the costs of those failing to comply, as well as timings, transparency around waste management fees and the responsibilities placed on online marketplaces.

“While the delay to EPR aims to give producers more time to prepare, the current regulations contain areas of ambiguity and potential concerns,” says George Atkinson, head of policy at Valpak. “This could be the last chance for businesses to make their voices heard on legislation that will affect generations to come.

 “Although costs have been discussed at policy level, large producers remain unclear on the potential scale of the base waste management fees they can expect to pay from October 2025. Publishing the costs that producers would have paid for local authority operations if EPR had been in place a few years ago would provide a level of transparency to help businesses budget.

“Similarly, the timing of mandatory labelling requirements has not been defined. Given the significant lead times associated with redesigning and bringing altered packaging to market, the date of implementation should be clarified as quickly as possible.”

With the implementation of EPR for packaging, producers – both brands and importers – will be charged with the full net cost of recycling. This includes the cost of collection, sorting and recycling. It is expected to raise compliance costs from £350 million to £1.7 billion per year. Soon after, eco-modulation will increase fees for those supplying unrecyclable packaging even further.

“In meeting the full net cost of recycling, there is a danger that those that comply with the legislation will be asked to bear the cost of ‘free riders’ – businesses which fail to meet their obligations,” Atkinson added. “In response, Valpak argues  the regulations should include safeguards to protect responsible businesses from the fees owed by the less scrupulous. We are also recommending a reconsideration of the exemption for online sellers under eco-modulation so all producers are affected equally.”

Atkinson also suggests greater differentiation between types of ‘producer’.

“Sellers are not required to pay waste management disposal costs, while some producers are only required to collect and report ‘nation of supply data’. To eliminate confusion, we believe it would be beneficial to define subcategories of seller.”

Other areas highlighted for debate include:

- The formats used for data forms to make them more user-friendly.

- Requirements on local authorities to report on performance.

- Provision for producers that have established takeback schemes for packaging commonly collected from households, or packaging such as flexible plastic which will eventually be collected.

www.valpak.co.uk