Defra has unveiled its latest proposals on extending producer responsibility (EPR) for packaging and introducing a deposit return scheme (DRS), aimed to boost recycling, reduce litter, as well as to improve packaging design and labelling.

This second phase of consultation is open until 4 June, leaving retail industry stakeholders 10 weeks to formulate their views and engage with the wider packaging supply chain and resources and waste sectors.

The third major reform around introduction of consistent recycling collections for all households and businesses in England, has not been published yet but will also be going out to consultation shortly.

The packaging changes are being developed on a UK-wide basis, while the Deposit Return Scheme will cover England, Wales and Northern Ireland. A separate scheme is already under way in Scotland, and administrations will work to ensure compatibility between the schemes.


First key elements from the lengthy consultation documents indicate that Defra reassessed the costs, now estimated to be in the region of £2.7bn - a more realistic yet still modest picture of how much businesses will be financially contributing to the reforms.

Defra outlines its approach to modulated fees based on the recyclability of packaging, the payments to local authorities and businesses for managing household packaging waste, payments for littered packaging waste.

There is also a proposal to have mandatory cup takeback and recycling requirement to be placed on businesses selling filled disposable paper cups to provide for the separate collection of used cups (either generated in-store or consumed ‘on-the-go’). This could be through both instore and front of shop collection points and would extend to accepting all disposable paper cups at these collection points irrespective of brand or where the drink was purchased.

To improve labelling, Defra suggests that broad requirements for labelling are set out in legislation, including a requirement to use a label approved by Government (or the Regulator). The consultation proposes mandatory recyclability labelling be introduced on packaging as soon as is feasible and by end of 2026/27 at the latest.

Defra is also minded reassessing the implementation timelines. It proposes to have a phased introduction for packaging EPR with initial payments for local authorities from October 2023 and further elements such as the modulation of fees, payments for the management of litter and payments to businesses for the cost of managing packaging waste, from 2024. For DRS, a roll-out in late 2024 at the earliest is now being consulted on.


The BRC welcomes the publication of the second RWS consultations and continues to share Government’s objectives of increasing recycling and recycled content, improving packaging design and labelling, tackling packaging waste litter and bringing more harmonisation into recycling collections. The UK needs a comprehensive and coherent Resources and Waste Strategy with a long-term strategy that builds infrastructure for all common materials and allows flexibility to incorporate future changes to our use of materials and provides consistency across all part of the UK.

The Government proposals in the EPR, DRS and consistency of collection consultations are intertwined with significant cost and regulatory implications for decades ahead for all stakeholders involved. As such, future design of the packaging EPR scheme must reflect value for money and overall system efficiency. And that given the substantial investment required from producers and retailers - estimated to be at least £2.7bn - it is essential to ensure that the future packaging EPR and DRS are future-proofed against changing shopping habits and don’t penalise responsible business practices (i.e. those who put the most environmentally friendly packaging on the market should not face hefty bills).

We wish to see this reform delivering substantial performance uplifts from all part of the resources and waste supply chain. The DRS needs to be well-designed scheme that will complement our existing kerbside collections. It is imperative to get its scope, design and operations right from the beginning to provide certainty and visibility for concerned businesses but also to alleviate the wider pressure on the retail industry from other regulatory and business taxation such as business rates.