The proposed reforms to the packaging Extended Producer Responsibility (EPR) system includes expanding producer payments to litter clean-up costs.
Whereas in the current system producer costs cover a market-share of recycling evidence, in theory EPR encompasses the ‘polluter pays principle’ to a far greater degree, covering the full net costs of recovery.
In many packaging EPR systems found globally, producers contribute funds for tackling litter. The current question for the UK EPR system, which is currently under review by Defra, is to what extent costs are taken away from the local authorities.
The recent consultation presented three options: that costs are shared amongst all producers; that the most littered items are assessed and costs shared accordingly; or as option 2, but brand prevalence is also accounted for. It’s also still not clear if these costs will just cover prevention activities, provisions of bins, or the clear-up of ground litter too.
Calculating producer contributions to litter clear-up
The EPR for packaging consultation itself stated “further work [is] required to determine these costs and would need to take account of the introduction of any DRS” providing the impetus for the research recently undertaken by Eunomia with WRAP. It’s important that the model accounts for the DRS, as in-scope containers for a deposit return scheme will form a significant proportion of items that may previously have been littered.
The Eunomia model considers costs reported through local authority revenue outturn reporting, variations in the street cleaning provisions by local authority, the perceived adequacy of allocated budgets to meet minimum statutory requirements, and the impacts of COVID-19.
Using these factors the report has provided an estimate for total litter clear-up costs of £662 million, and also an estimated figure by material type. Nearly 60% of the estimated total costs was attributed to packaging waste.
The model may be used by Defra in their final assessment of producer contributions to litter clear-up. The more accurate the estimates, the more reflective these fees will be. Depending on the degree to which government decide producers should be responsible, the model can give a better idea of what kind of costs can be expected.
It’s also worth noting that the report states "EPR fees could cover cost of improvements in data collection that would facilitate the determination of costs", so as better waste data is achieved nation-wide the model may become more robust.
A highly contentious issue for producers
Senior Analyst at WRAP, who collaborated on the project, Billy Harris has said “This is an innovative piece of work that represents a major step towards understanding the cost of litter management to UK local authorities and other statutory bodies. It will play an important role in informing the debate around litter costs in the context of Extended Producer Responsibility.”
Director of innovation and policy at Ecosurety, Robbie Staniforth, commented "The magnitude of littering costs that producers should cover is highly contentious, given that packaging doesn’t litter itself. These findings show that only 35% of total costs come from bin litter as opposed to ground litter clearance. We would hope that a new EPR system directs a higher proportion of funding to on the go recycling bin provision to proactively reduce the prevalence of ground litter."
"We welcome the research findings that shows nearly half of littered items are not packaging. While street cleansing services will no doubt welcome funding from producers for their activities, they will be looking to Government for a solution to their funding gap for non-packaging littered items, once the new EPR system is introduced."
As Policy advisor Louisa provides key support to our team, including preparing reports on environmental policy issues and maintaining awareness of new developments. As such she will often be found coordinating responses to policy consultations, advocating policy positions and providing internal guidance to current legislation.