Packaging Extended Producer Responsibility Statement - Nov 24

British Glass is extremely disappointment that the packaging Extended Producer Responsibility scheme (pEPR) regulations were passed by the Delegated Legislation committee in Parliament on Wednesday 27th November 2024 without any challenge from MPs.

This is despite the serious issues that British Glass has raised with MPs and Ministers on the negative impact they will have on the environment and the glass sector.

British Glass supports the principle of pEPR and that packaging waste collection and recycling needs to be reformed to deliver a circular economy for the UK.

However, the current pEPR regulations will not deliver this and will negatively impact UK businesses including glass packaging production.

The proposed pEPR fees are primary based on weight meaning glass packaging will bear around 30% of the total cost, which is approximately £500m based on the intermediate pEPR fee, whilst being less than 5% of the packaging placed on the UK market by volume.

At the debate yesterday evening Recycling Minister Mary Creagh stated: “As we look at the global plastic pollution treaty negotiations in Busan, South Korea, we certainly hope to play our part in that work.” 

Unfortunately, pEPR as it stands will work against this. The aim of pEPR is to drive away from difficult to recycle packaging materials to recyclable packaging materials, the current policy will incentivise the move away from glass packaging to less recyclable materials such as plastic packaging. When the proposed pEPR fees are calculated on units of packaging, as packaging is bought on units not weight, this will distort the packaging market as glass will have a substantial pEPR fee compared to competing packaging materials.  Glass is 100% recyclable and is infinitely recyclable as it does not deteriorate on each recycle.

In addition, metal and plastic beverage packaging will not be within the scope of pEPR as they will be within a Deposit Return Scheme (DRS) from October 2027, so will not be subject to pEPR fees and will have a waste policy cost advantage for over two years, whilst glass beverage packaging will have pEPR fees from April 2025. 
As 80% of glass packaging is beverage packaging this will have significant impact on glass packaging. Given all the uncertainty and delays around DRS, especially considering the Welsh Government’s decision to withdraw from a UK wide scheme, it is vital that in scope DRS materials also pay pEPR fees until a DRS scheme is in operation. 

In terms of price changes, a 330ml glass beer bottle will have a pEPR fee of approximately 5p, with the addition of supply chain margins and VAT, the consumer will see at least a 10p increase in a beer bottle, whilst metal and plastic beverage packaging will not be affected.  This will lead to inflation for the consumer or probably more likely a switch away from glass packaging.  We have already experienced the impact of brands moving away from glass, as they are now purchasing their packaging for 2025.

Minister Mary Creagh quoted in the Delegated Legislation committee that the burden of waste collection will be moved away from the taxpayer to the Producer.  This is misleading as Producers will not be able to absorb the pEPR cost for glass packaging and will pass it on to the consumer or move out of glass packaging to less recyclable packaging materials.

In addition, there has been an increase in the imports of empty glass packaging from countries outside of the EU and these countries are producing more carbon per a unit of glass packaging.  These imports can be at least 20% cheaper than UK produced glass packaging and will be able to absorb the pEPR cost which will lead to more imports and a negative impact UK glass production, and ultimately more carbon into the global atmosphere.