Extended Producer Responsibility (EPR) policy driving sustainable packaging

6 January 2023


Both the EU and UK have set 2024 as the target for full compliance with their respective Extended Producer Responsibility (EPR) schemes. This gives food suppliers an added incentive to switch to more sustainable packaging. But how can you be sure these new packaging options are fit for purpose as well as compliant with Extended Producer Responsibility regulations?


Each jurisdiction tends to have their own variants of Extended Producer Responsibility regulations.  The latest Extended Producer Responsibility UK 2023 guidelines are published on DEFRA's website.


EPR schemes are designed to transfer the cost of collecting, reprocessing and recycling packaging to producers and importers, rather than local government authorities in the case of EPR legislation UK.


By EPR legislation shifting the responsibility, either fully or partially, it’s hoped that organisations across the retail chain will be motivated to use packaging that’s reusable and easy to recycle at the end of a product’s shelf life.


Given that most food packaging is single use, EPR has significant implications for the sector. Yet, although many of the food giants are already committed to sustainability and have been getting ready for the formal introduction of EPR regulations for some time, SMEs are arguably less well prepared.



But it’s important that every company, irrespective of size, gets to grips the new legislation. Failure to provide evidence - in the form of purchased Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs) - that an equivalent weight of packaging has been recycled is likely to result in a double financial hit; a fine for not submitting the relevant data plus a back dated bill for all the packaged goods supplied and handled from the beginning of 2023. 

There’s also an additional annual fee that companies must pay to the environmental regulator, depending on their turnover and total weight of packaging handled. And let’s not forget that EPR is in addition to the plastic taxes currently in force and refers to all packaging materials, renewable or otherwise. 

So it’s perhaps not surprising that some of these new costs may eventually be passed on to the consumer; adding as much as 0.6% to the average shopping basket according to some calculations. Such an increase is understandably cause for concern, particularly given today’s historically high inflation and cost of living crisis. However, there are ways to mitigate the impact of EPR.

Managing change


Using more lightweight materials, rather than rigid glass bottles and jars or metal cans and tins, is one option that’s also highly relevant for companies handling close to the EPR threshold of 500 tonnes of packaging per year. Although ‘light weighting’ has long been an effective strategy for reducing fuel and transport costs, it’s now taken on even greater significance in light of PRN costs and the need to reduce carbon footprint. 

Switching to recycled and biodegradable packaging materials is another important consideration. They are charged at a lower PRN rate than plastic which, as you would expect, is at the top of a rapidly rising price scale – again, underlining the fact that the EPR framework rewards sustainable packaging choices.

In practical terms, this means that a small beverage manufacturer, with a turnover exceeding £2 million, could potentially reduce annual packaging tonnage to a level that avoids EPR altogether. And if at least 30% of recycled plastic is used, it could also be exempt from the plastic tax.

At the same time, it’s important to recognise that making changes to packaging formats and/or materials may not be straightforward. More sustainable alternatives must still perform the same principal functions as the existing packaging. That is:

  • Protect the contents of the packaging after filling; during transport, storage and throughout shelf life right up to the point of consumption


  • Be compatible with the existing plant operation and machinery


  • Provide an easy to open and, in many cases, resealable mechanism


  • Advertise contents and required information to the consumer, such as ingredients lists as well as how the packaging should be recycled or disposed



What this means is that the current legislative drive towards greater sustainability has added a new layer of complexity to food packaging strategies. It’s also challenging traditional packaging formats and inspiring new innovations in the form of eco-friendly materials, technologies and formats. And it means that RSSL’s comprehensive analytical testing expertise is more important and in demand than ever.

Why? Because changing product packaging to use less, thinner or more sustainable packaging materials can create a number of issues. Barrier properties and shelf life, along with pack integrity, robustness and seal strength can all change. Any unaccounted changes can compromise the function of packaging during production, transit, storage and use. So, every aspect must be thoroughly assessed using relevant analytical methods that consider both product and packaging. If not, quality standards may not be maintained; risking consumer complaints and even damaging brand reputation via a food safety issue. 

Putting packaging to the test


For instance, switching to a new compostable flexible film is likely to bring different barrier properties that could affect the taste, appearance or odour as well as shelf-life and safety of the product it houses. Only by measuring the oxygen and moisture transmission rate through the film can we be show that it provides the optimal barrier protection during shelf life. 

It’s also vital that analytical testing is carried out under conditions that replicate the journey through the entire supply chain. This is particularly important when it comes to biodegradable materials which, by their very nature and purpose, are expected to have a finite lifespan – but must still perform their functional role until the end of the product’s shelf life. By aging the materials and packaging at temperatures and humidity that mimic different environments, we can evaluate their mechanical and barrier properties to ensure these expectations are met.

These tests should also consider every element of the new packaging concept. Don’t forget, EPR legislation applies to even the smallest packaging components, from caps, strapping and tapes to adhesives, closures and tethers. So, the same rules apply. Mechanical testing will show if the sustainable alternatives function in the same way, while more expensive haptic consumer studies can verify their suitability in use.

Interestingly, 2024 also marks the introduction of new EU legislation that sets out the requirement for caps of non-returnable plastic bottles to remain tethered even after opening. A move that has further implications for testing strategies. which now need to now need to evaluate whether the cap connection is strong enough to remain in place through product use, disposal and the recycling chain. Again, RSSL can respond to this with tailored testing methods that will confirm whether the force needed to break the tether is sufficient for compliance purposes. 

Thinking outside the box


Despite making progress towards greener packaging, much still needs to be done to achieve the goal of true circularity; where recycled materials are used for the same purpose for which they were originally used an infinite number of times.

One of the biggest issues is that the quality and properties of recycled materials degrade over time. There are also concerns about potentially harmful impurities making their way into the recycling process and migrating into food. At the same time, the materials themselves need to meet certain recyclability standards to ensure they don’t contaminate waste streams.

Targeted analytical testing can help answer these - and many other - important questions. It plays a fundamental role in ensuring the quality of recycled materials and packaging remains fit for purpose. And takes you one step closer to a successful sustainable switch. 



How RSSL can support with packaging testing


RSSL’s comprehensive packaging testing service is designed to evaluate a broad range of materials and formats across primary and secondary packaging categories. These include evaluating material mechanical and physical properties, such as barrier protection, ease of opening and mechanical strength, as well as material analysis including microscopy, and spectroscopy techniques. Our technical experts can evaluate the impact of the packaging on product shelf life as well as the potential impact of the packaging on the product with potential tainting compounds, due to low barrier protection or tainted raw material. Click through to find out more or contact us below.

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