The packaging waste regulations reform feature 4 core initiatives, all announced in early 2019

The intention is that all stakeholders become part of the movement to tackle climate change by providing increased financial incentives to drive even more innovation in packaging, even greater efficiency and an even stronger infrastructure, and all underpinned by increased consumer awareness and participation

It is important to understand how these could affect you and your business

In the sections below we discus in more detail each of these topics and include references for further reading

• Plastic Packaging Tax (PPT) will be a tax on plastic packaging produced or imported that does not contain at least 30% recycled content
• Extended Producer Responsibility (EPR) will be where producers’ become financially responsible for funding the total costs associated with dealing with packaging waste
• Deposit Return Scheme (DRS) where a deposit is to be added to beverage packaging that consumers can then claim back when they return to a recycling point

Macpac position on 2024 EPR regulations

The new extended producer responsibility for packaging regulations, designed by DEFRA, came into effect in 2024. They are lengthy, complicated to understand and even more complicated to implement. Many organisations are advised by expert compliance consultants.
This content aims to briefly overview the regulations and explain how Macpac has responded to them.

What are the aims of the 2024 EPR rules?

The EPR regulations aim to reduce unnecessary packaging and increase the circularity of packaging¹.
This is achieved by two taxes:

• PRNs generate funding for recyclers to improve recycling infrastructure
• Waste Management Fees provide additional funding to councils for their collection and sorting of household waste.

These fees place a significant burden on producers. Waste management fees alone are estimated to generate £1.5bn in 2024².

Who pays EPR taxes?

Under these new rules, one organisation within a supply chain is responsible for reporting an item of packaging and paying the taxes. Under the previous 2007 regulations, the taxes were distributed throughout the supply chain.
Establishing who within a supply chain is responsible for reporting an item of packaging is not straightforward. The tax burden is placed on larger companies³. The hierarchy of which organisation pays the tax for an item of packaging is:

A company is considered ‘large’ if it has a turnover of £2m+ and supplies over 50 tonnes of packaging a year.⁴
Packaging is exempt from EPR taxes if there is no large company in the supply chain. In a supply chain with a mix of small and large companies, the large company in the above hierarchy is the EPR taxpayer. However, complex supply chains make identifying the correct company challenging.

How are the taxes calculated?

PRNs are paid on all packaging that a large producer has reported. Waste management fees are only paid on packaging a large producer reports that ends up in household waste or public bins.
PRN prices vary with the market cost of recycling by material. Waste management fees are defined by the government by material and year; and are £423/tonne for plastic in 2025⁵. From 2026 onwards, these fees will be modulated depending on how recyclable packaging is. Harder to recycle packaging will attract higher fees. Easily recycled packaging like ours, will receive a discount.

How is Macpac responding to these taxes?

The packaging Macpac makes is already highly competitive within the EPR framework. Our thermoformed RPET plastic packaging is lightweight, easily recyclable, and low carbon footprint. We continue to work closely with our clients to help them make decisions that lead to sustainable and EPR efficient products.

Help needed?

Please speak with us if you have any EPR related questions about your existing or future projects. We will help you understand the regulations, and help you make design decisions to reduce their burden.

¹Pack UK interim strategy (Gov.uk)
²EPR for packaging updated illustrative base fees December 2024 (Gov.uk)
³How to collect your packaging data for Extended Producer Responsibility (Gov.uk)
⁴Extended Producer Responsibility for packaging. Who is affected and what to do (Gov.uk)
⁵Extended Producer Responsibility for packaging 2025 base fees (Gov.uk)

The UK government have released what they call ‘public consultations’ to gain stakeholder and public opinion which are then considered when shaping the regulatory outcome.

The second consultation for the Plastic Packaging Tax (PPT) in England, Scotland, Wales and Northern Ireland ran from 11th March 2020 to 20th August 2020, it will become part of the Finance Act 2021 after Royal Assent/

What it hopes to achieve:

• Encourage greater use of recycled plastic
• Minimise unnecessary use of virgin materials
• Tackle the issue of plastic becoming waste

What to expect?

• This tax is due to come into affect on 1st April 2022
• All plastic packaging will be liable for this tax unless it is shown to have at least 30% recycled content
• Both pre and post consumer waste can be used to make up the 30% recycled content
• This will apply on top of current PRN costs if you are obligated and in the future it will be on top of the producers’ EPR and DRS costs
• Fortunately at Macpac our rPET material already contains at least 80% recycled content made up of pre-and post consumer recyclate, so all our clients who use our rPET will be unaffected by this tax (it will just mean more paperwork on our side!)

The UK government have released what they call ‘public consultations’ to gain stakeholder and public opinion which are then considered when shaping the regulatory outcome.

The second consultations for the UK Deposit Return Scheme (DRS) in England, Wales and Northern Ireland were released by UK governments on 24th March 2021 and closed on 4th June 2021

We give our understanding of the regulations so far:

What it hopes to achieve:

• Change consumer behaviour and therefore increase the recycling rate of drinks containers
• Reduce littering
• Generate higher levels of good quality recycled materials

What to expect:

• PET plastic bottles, glass bottles, aluminium cans and steel cans are the products in scope
• There is the potential for material collected by the DRS system to go back to the obligated producers that are funding the system
  1. This would reduce the supply of good quality post consumer recyclate for all other non-beverage markets for the materials in scope
  2. Reduced supply could drive up costs for recycled content
  3. Could increase the need for more virgin material to keep quality high

Still to be decided:

• How the scheme will operate
• The scheme scope and design
• Implementation timelines
• Enforcement

This content is being updated. Please check back soon.