EPR 2025: How Facility Managers Can Navigate New Packaging Waste Legislation In The UK
Extended Producer Responsibility (EPR) is a legal framework designed to hold producers accountable for the costs associated with collecting, managing, and recycling packaging materials.
Set to begin implementation early this year, it encourages businesses to recycle more by applying modulation fees based on a product's recyclability.
In essence, the government uses fees to incentivise companies to reduce environmental impact, with more recyclable products incurring lower fees.
By March 31, 2025, non‑household premises (except 'micro‑firms' with fewer than 10 full‑time equivalent employees) will be required to recycle all recyclable waste streams, including plastic, metal, glass, paper/card, and food waste.
The impact of plastic waste has come under scrutiny, with the introduction of the plastic packaging tax. Ultimately, EPR seeks to promote circularity in recycling and waste management, with Defra spearheading this legislation.
For facility managers, this means understanding the new rules, ensuring compliance, and adopting smarter waste strategies to stay ahead of the curve. Here’s what you need to know about EPR going into 2025.
EPR Fees And Operator Responsibilities
Most operators won't be directly affected by EPR data reporting and fees. Companies exceeding £1 million turnover and 25 tonnes of eligible packaging annually must report their market‑placed packaging biannually. Those with over £2 million turnover and 50‑plus tonnes will pay “modulated fees” based on quantity and recyclability.
Branding is crucial: if your brand appears on the packaging, such as cups, it counts towards your tonnage. Unbranded cups and packaging are the manufacturer's responsibility.
Even if you're not directly liable, your suppliers will be affected. EPR fees will add over £1 billion annually to packaging manufacturers' and importers' costs, likely triggering price increases throughout 2025.
Fibre‑based packaging fees (including paper cups), start in April 2025. The Automatic Vending Association (AVA) and Alliance for Fibre‑Based Packaging (AfBP) are working with Defra to refine these costs, with estimates suggesting an additional 1p to 3p per cup.
Cancellation Of Mandatory Cup Takeback
The UK Government has abandoned plans to mandate businesses to recycle single‑use cups as part of the extended producer responsibility for packaging regulations.
The policy would have required businesses selling drinks in fibre‑based composite (FBC) cups and employing at least 10 full‑time staff to provide on‑site collection bins, arrange for recycling, and report cup sales and collection weights to regulators. Defra cited excessive costs (£52 million) and limited environmental impact as reasons for cancellation.
However, this decision may increase the likelihood of a UK‑wide 'single‑use cup levy', similar to Scotland's approach. FMs and operators should continue to work with clients and their existing waste contractors in accordance with 'Simpler Recycling' guidelines.
Deposit Return Scheme
Defra recently reaffirmed its commitment to launching a Deposit Return Scheme (DRS) in October 2027. Regulations for England and Northern Ireland have been announced, allowing for the appointment of Deposit Management Organisations in April 2025.
The AVA and its members support a single, effective DRS for PET bottles and cans across the UK. AVA's lobbying efforts have influenced Defra's current profile, which states that premises with only vending machine sales of in‑scope drinks containers wouldn’t be compelled to operate a return point.
However, as this exemption isn’t yet legally binding, continued lobbying is necessary to ensure vending and automated retailing remain exempt.
Paper Cup Levy
Scotland plans to implement a 'Single‑Use Cup Levy' in Spring 2026. The recent consultation proposed exempting vending machine drinks, while all other businesses must charge a levy on single‑use cups, regardless of material. The proposed levy ranges from 20p to 50p or more, with the Scottish government planning to publish a response summary in February 2025.
The Simpler Recycling policy in England impacts all AVA members’ business premises, regardless of their membership category. For FMs, the responsibility lies with the client company, which should have a commercial waste contract in place.
At the AVA we share regular updates with our members on changes to the EPR legislation, so they are always up to date on the current prices and dates of implementation. When you work with an AVA member, you are safe in the knowledge that your operator is working in accordance with current guidelines.
How FMs Should Prepare
To comply with the UK’s new EPR regulations, FMs should take the following actions:
- Understand EPR legislation
Familiarise yourself with EPR regulations applicable to your sector, staying updated on obligations and enforcement details from government and industry bodies. Identify materials in your facility that fall under EPR obligations.
- Audit waste and materials
Evaluate the types and volumes of waste and materials produced and current end‑of‑life handling processes for materials. Target areas heavily impacted by EPR, such as single‑use plastics, non‑recyclable packaging, and e‑waste.
- Collaborate across departments and vendors
Work with procurement to identify suppliers that use EPR‑compliant sustainable packaging. Ensure waste vendors support proper sorting and recycling and educate staff on effective waste reduction and sorting practices.
- Implement sustainable practices
Adopt reusable options and introduce a circular economy approach, like equipment repair and refurbishment before disposal. Improve waste segregation with clearly labelled bins and source sustainable products and packaging.
- Optimise data management
Establish systems to monitor volume, type, and disposal methods to track and document waste streams. Maintain compliance records of all EPR activities and use technology for waste tracking and reporting.
- Budget for compliance
Factor in expenses for sustainable upgrades and compliance training. Consider infrastructure investments needed for better waste management and apply for relevant government incentives.
- Develop and execute a communication strategy
Communicate EPR benefits including cost efficiency and enhanced reputation to leadership and relevant parties. Share progress in sustainability to reinforce commitment to environmental stewardship.
- Evaluate and improve continuously
Conduct periodic reviews of waste reduction efforts and benchmark your efforts against industry standards. Stay informed about potential regulatory changes to avoid last‑minute compliance challenges.
- Partner with the right organisations
At the AVA, our members are supported for EPR though our network, with regular updates and guidelines on what they need to do in preparation for these changes. Having partnerships with vendors that are in the know and ready is essential for success.
Additional Advice
Ideally, facilities managers should engage with industry groups such as IWFM which are focused on EPR and sustainability to network and share best practices. Highlight the broader benefits of your compliance efforts, including environmental contributions and carbon footprint reduction.
At the AVA we are in full support of the new EPR legislation and have been in talks with Defra for a number of years about the specific elements and how they will impact our members. EPR should not feel like a burden on FMs shoulders, but rather an opportunity to refine sustainability practices.
To gain access to expert support, industry insights, and a network of professionals, visit the AVA website at www.the‑ava.com
Click the article to enlarge it.
