Understanding EPR
With EPR, DRS, ECGTD, GCD, and probably more to come, there’s a flood of random collections of letters, also known as acronyms, for drinks producers to get their heads around over the next few years. In our last post we explored the UK’s upcoming Deposit Return Scheme (DRS) and this week we’re looking into Extended Producer Responsibility (EPR)
Understanding Extended Producer Responsibility (EPR)
EPR extends a producer’s responsibility for a product to the post-citizen stage of its lifecycle. In the context of packaging, this means that producers are obligated to manage the disposal and recycling of packaging materials they introduce into the market. The primary objective is to incentivise producers to design more sustainable packaging and to reduce the environmental footprint of their products.
Key Dates and Implementation Timeline
The EPR for packaging was initially scheduled to commence in 2024. However, after consultations and industry feedback, the UK government deferred the implementation of EPR fees by a year. As a result, producers are not required to pay any EPR packaging fees in 2024. Nevertheless, businesses must still collect and report their packaging data for 2023, with the first reporting deadline set for 31 May 2024. The EPR fees will be payable from October 2025, based on the data collected for the 2024 calendar year. (gov.uk)
Scope of EPR Regulations: Inclusions and Exclusions
The EPR regulations encompass all types of packaging introduced into the UK market, regardless of the material used. This includes primary packaging (directly containing the product), secondary packaging (used for grouping products), and tertiary packaging (used for bulk handling and distribution). For beverage producers, this means that bottles, cans, labels, caps, shippers, and any additional packaging components are subject to EPR obligations.
For small producers, you need to collect and report packaging data for a given year if all the following apply:
• Your business’s annual turnover exceeds £1 million (based on your most recent accounts)
• You handle more than 25 tonnes of packaging in a calendar year.
• You perform any of the packaging activities listed in the regulations.
If your business falls below these thresholds, you are not required to report under the EPR regulations. (gov.uk)
However, it’s important to note that from 2024, annual data reporting requirements will require ‘small producers’ to declare what packaging they have handled. If your business is affected, you likely need to collect data on the amount and type of packaging you handle now in preparation for reporting next year. (valpak.co.uk)
The Technical Side of Recyclability: Understanding the UK’s RAM and RAG System for Drinks Packaging
As Extended Producer Responsibility (EPR) legislation begins to reshape packaging compliance in the UK, under EPR, producers will be charged modulated fees based on the real-world recyclability of each packaging component.
This is where the Recyclability Assessment Methodology (RAM) comes into play, providing a standardised, data-led process to determine how packaging performs within the UK’s waste management systems. The methodology also feeds directly into the Red-Amber-Green (RAG) classification system, which determines the fee bands under EPR.
What is the Recyclability Assessment Methodology (RAM)?
The RAM, developed by Defra in partnership with WRAP and industry stakeholders, is a structured decision framework for evaluating whether a packaging format is:
• Recyclable at scale (green),
• Recyclable with limitations (amber), or
• Problematic Packing (red).
This categorisation is based not just on material type, but on real-world evidence of how packaging is collected, sorted, and reprocessed within the UK’s infrastructure.
The Four Technical Stages of RAM
1. Collection Compatibility
• Is the packaging material accepted in >75% of UK kerbside or household recycling collections?
• Data is drawn from WRAP’s local authority collection datasets.
2. Sorting Compatibility
• Can the item be reliably detected and separated at a Material Recovery Facility (MRF)?
• NIR (Near-Infrared) detectability, size constraints (typically >40mm), and material behaviour during mechanical sorting are key considerations.
3. Reprocessing Feasibility
• Is there a proven reprocessing pathway for the item within the UK?
• This includes mechanical recyclability, compatibility with existing washing/sorting lines, and absence of contaminating components (e.g. inks, glues, laminates).
4. End-Market Viability
• Is there a stable, commercially viable market for the resulting recycled material?
• For example, rPET from clear bottles has a strong end-market, whereas coloured PET has limited applications.
Each stage acts as a filter: if a material fails at any stage, it is downgraded in the RAG classification.
Applying RAM to Drinks Packaging Materials
Let’s explore how the RAM assesses typical drinks packaging formats:
🟢 Green – Recyclable at Scale
Glass bottles with a cork, clear PET bottles and aluminium cans typically score green:
• Widely collected (>95% of councils)
• Readily sorted using NIR (PET) or eddy current separators (aluminium)
• Reprocessed through established systems
• Strong demand for recycled content (e.g., glass cullet, rPET or recycled aluminium)
Design Caveats:
• PET must be clear and free from full shrink sleeves
• Labels should be <40% of surface and made from floatable materials
• Adhesives must be water-soluble
🟠 Amber – Recyclable with Limitations
Glass bottles with ROPP caps:
• Despite being widely collected, DEFRA has indicated that glass bottles where the aluminium ring that remains on the bottle, will fall into the amber category
•. Glass bottles with complex labels or ceramic inks may also be downgraded to amber due to potential contamination during reprocessing.
Tetra Pak-style paper-based cartons fall here:
• Collected by ~70% of authorities (below the 75% threshold)
• Specialist reprocessing is required to separate paper, plastic and foil layers
• End-markets exist but are regionally limited
Coloured PET bottles also fall into amber:
• Technically recyclable but with reduced end-market value
• Black PET often fails NIR sorting unless NIR-detectable pigments are used
🔴 Red – Not Recyclable at Scale
Formats that fail to meet collection, sorting or processing criteria fall into red. These include:
• Flexible plastic pouches and multilayer laminates
• Opaque or carbon black plastics that evade NIR sorting
• Composite formats that cannot be mechanically separated (e.g., plastic-lined paper cups)
Red packaging incurs the highest EPR fees, as it imposes greater environmental and waste management costs on the system.
Supporting Tools and Evidence Sources
If you do not know what the packaging you supply is made of or are missing other technical details that you need to complete the assessment, contact the packaging manufacturer.
To ensure consistent application of RAM, the UK government and its partners have developed the following resources:
• WRAP’s Recyclability Guidance – Material-specific technical advice for improving recyclability.
• OPRL Guidelines – On-pack labelling rules aligned with the RAM and RAG system.
• Technical Evidence Submissions – Brands can submit evidence if they believe a format should be upgraded from amber/red.
Implications for Beverage Producers: Packaging Adjustments
Under the EPR framework, producers will bear the full net costs associated with the collection, sorting, recycling, and disposal of packaging waste. This shift from the previous shared responsibility model means that beverage producers need to re-evaluate their packaging strategies.
To mitigate potential costs, you can consider the following actions:
1. Material Selection: Opt for materials that are widely recyclable and have established recycling streams. The good news here is that glass (bottles) and aluminium (cans) are widely recycled across the UK.
2. Design for Recycling: Simplify packaging designs to reduce the use of mixed materials, which can complicate the recycling process. Avoid using non-recyclable components like certain adhesives or multi-layered materials.
3. Lightweighting: Reduce the weight of packaging without compromising product integrity. Lighter packaging can lead to lower material costs and reduced EPR fees.
4. Circular Solutions: The best way to avoid EPR costs is to reduce single-use waste packaging through utilising circular packaging solutions such as ecoSPIRITS or refill systems. We anticipate these will become more popular due to the impact of EPR.
By proactively adopting these strategies, beverage producers can not only comply with EPR regulations but also position themselves as environmentally responsible brands, which can enhance consumer loyalty.
Financial Considerations: Anticipated Costs
The transition to EPR is expected to have significant financial implications for producers. Estimates suggest that the total costs for all organisations could be around £1.7 billion per year, a substantial increase from the previous Packaging Recovery Note (PRN) system, which ranged between £200-£300 million annually. (anthesisgroup.com)
These costs will vary based on several factors:
• Packaging Volume: The more packaging a producer places on the market, the higher their financial obligation.
• Material Type: Materials that are difficult or costly to recycle may incur higher fees. Conversely, using easily recyclable materials, can result in lower costs.
• Recyclability: Packaging that is not recyclable or contaminates recycling streams can attract higher charges.
The Department for Environment, Food & Rural Affairs (Defra) has provided illustrative base fees for the 2025-2026 period, which vary depending on the material type. As of writing the 3rd release published in December, for the materials commonly used in the drinks industry, the estimated fees per tonne are as follows:
Glass:
• £240
Aluminium:
• £430
Paper and Cardboard:
• £215
These fees are indicative and subject to change as the EPR framework is finalized. The ranges reflect different scenarios considered by the government regarding local authority disposal costs. The intermediate figures represent the central case scenario. (gov.uk)
It’s crucial for producers to conduct a thorough analysis of their packaging portfolios to understand potential cost implications and to identify opportunities for cost savings through sustainable packaging choices.
Industry Response and Calls for Delay
The introduction of EPR has elicited significant concern within the beverage industry. Over 80 wine and spirits businesses have petitioned the UK government to delay the implementation of the EPR scheme, citing concerns over the financial burden and the readiness of the necessary infrastructure to manage the increased recycling responsibilities. (just-drinks.com)
With all the incoming legislation, COG’s and energy price increases, a downturn in demand due to the cost of living crisis, and an uncertain global economy, there is an argument to delay implementation until the industry is a more robust state.
Summary
Extended Producer Responsibility legislation is set to transform how packaging waste is managed, shifting the full cost of recycling and disposal onto producers. From 2025, businesses producing packaging—including glass bottles, aluminium cans, and cardboard boxes—will pay fees based on the recyclability and volume of materials they introduce to the market.
While this represents a financial adjustment for drinks brands, it also encourages more sustainable packaging choices, driving the industry towards a circular economy. By prioritising recyclability and waste reduction, the sector has an opportunity to lower costs, improve sustainability credentials, and contribute to a cleaner environment.
But just like other newly rolled out government legislation, the devil is in the execution and support provided to brands to work through the changes, and we’re not yet convinced that the UK government has done enough to provide clear guidance or support an industry that’s already on its knees from the Covid and cost of living crisis.
