The Environmental Industries Commission (EIC) have responded to the Department for Environment, Food and Rural Affairs' (Defra) consultation on the draft Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. We view this consultation as a crucial opportunity to shape the landscape of environmental responsibility and sustainability. While we trust that much of the draft regulations are clear, we are concerned that there are still key areas where further clarity is necessary, and that effective interaction and efficient interfaces are pivotal for achieving optimal outcomes.

Simplifying Interfaces: The Key to Efficiency

Efficiency in environmental regulations is not just a buzzword; it's a necessity. The EIC acknowledges the proposed fee modulation system but believes that it needs to be simplified. Complex interfaces can hinder the effectiveness of the EPR scheme. To achieve the desired outcomes, we call for a streamlined and transparent fee modulation system that businesses can easily comprehend and navigate. Simplification is not just about making things easier; it's about ensuring that businesses are incentivised to participate fully in achieving sustainability goals.

Driving Desired Outcomes: Innovations and Capacity Building

To realise the desired outcomes of EPR, we must think beyond regulation. The EIC believes in fostering innovation and capacity building. This includes supporting local authorities and the private sector in their efforts to collect and recycle packaging waste. It's essential to provide them with the resources and support they need to succeed. Moreover, we advocate for the development of innovative solutions that reduce the generation of packaging waste, thus lessening our environmental footprint. By focusing on these aspects, we not only ensure effective interaction and efficient interfaces but also drive sustainable practices that will benefit us all.

A Call for Clarity: Ensuring Effective Interaction

At the heart of EPR's success lies the need for effective interaction between stakeholders. It is imperative that businesses, compliance schemes, and regulators work together seamlessly. However, this can only be achieved if there is absolute clarity in the roles and responsibilities of each party. To this end, the EIC is seeking greater clarity regarding the role of compliance schemes in assisting businesses in meeting their EPR obligations. We emphasize the importance of businesses understanding the range of services that compliance schemes can provide. We firmly advocate for the creation of a transparent and independent body to oversee the accreditation and oversight of these compliance schemes, ensuring that interactions are not only effective but also fair and equitable.

In this transformative era of environmental consciousness, the Environmental Industries Commission remains steadfast in its mission to forge a more sustainable future. By emphasizing effective interaction, efficient interfaces, and innovation, we can chart a course towards a greener world where environmental excellence is the norm.

EIC’s Waste and Resources Taskforce looks forward to continued engagement with Defra and other stakeholders to refine and implement the EPR for packaging framework successfully.

SUEZ - “The policy delays are a real concern for the sector, inhibiting much needed investment in NetZero, circular solutions and resource efficient infrastructure and services, and pushing the heavy lifting into a shorter window from 2030 onwards. Simplifying the user experience is welcomed, but ensuring polluters pay and that packaging is better designed to be reused, refilled, repaired and ultimately recycled is key, so finishing off the years of work on EPR is vital to underpinning the much needed transition of our sector and enabling potentially 250,000 new green jobs into our undervalued sector, a sector that will support many other sectors as they look to deliver NetZero policies.”

SLR Consulting - “We are supportive of the EPR initiative and whilst consultation is an important stage in making sure that implementation is effective and garners broad support, it is also crucial that policy initiatives such as EPR are delivered in a timely fashion to remove uncertainty and give confidence to all stakeholders as well as enabling businesses to adapt, invest and grow sustainably.”