Scottish Government estimates £951m cost for packaging EPR reform

Comprehensive assessment reveals economic costs will be offset by environmental gains as Scotland transitions to full producer responsibility for packaging waste

Beth Jones | 15 November 2024

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The Scottish Government's final Business and Regulatory Impact Assessment (BRIA) reveals implementing Extended Producer Responsibility (EPR) for packaging will cost £951.05 million over ten years from 2025, with monetised benefits of £934.03 million.

The current system requires producers to purchase Packaging Waste Recycling Notes to meet recycling obligations, covering only 10 per cent of waste management costs. The BRIA confirms this will shift to full producer responsibility for household packaging waste from 2025.

The assessment's economic analysis shows producers will pay £864.34 million for household packaging waste management and £29.71 million for Household Waste Recycling Centres between 2025-2034. Additional costs include £11.53 million for the Scheme Administrator and £13.21 million for regulatory oversight.

Economic assessment reveals long-term value

The BRIA calculates the Net Present Value (NPV) by comparing total costs against projected benefits over the ten-year period. The negative NPV of £17.02 million indicates that monetised costs exceed quantifiable benefits by this amount when future values are converted to today's prices.

However, the assessment emphasises this figure excludes significant environmental and social benefits that cannot be readily converted to monetary values. These include reduced greenhouse gas emissions, valued at £14.58 million, and additional unquantified benefits such as lower virgin material usage and improved recycling infrastructure.

Local authorities stand to receive £894.05 million over the decade to cover collection, sorting, treatment and disposal of household packaging waste. The system requires councils to demonstrate their services are efficient and effective to receive funding.

Consumer impact and implementation timeline

The BRIA projects household costs will rise between £28.02 and £56.04 annually, with a central estimate of £47.64, as producers pass on their increased costs. This equates to between 54 pence and £1.07 per week for the average household.

Implementation begins with base fees in 2025, followed by modulated fees from 2026 that will vary based on packaging recyclability. The Scottish Environment Protection Agency will oversee compliance and enforcement.

The government aims to increase packaging recycling rates to 76% by 2030 through the reforms. The BRIA indicates this target, alongside other environmental benefits, justifies the economic investment in transforming Scotland's packaging waste system.

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How will the government and DMOs address the challenges of including glass in DRS while ensuring a level playing field across the UK?

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There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.