Jude Allan explains why new mandatory labelling laws for all packaging products will help consumers engage in recycling
Our lives are full of messages. In a world brimming with information, the most effective brand communications cut through the chatter to engage customers, position the brand among its competitors, or impart useful information or instructions. A greater consumer focus on sustainability, coupled with brand-new legislation, is no exception when it comes to messaging.
At OPRL, we have always promoted the importance of clear labelling to encourage consumers to recycle at home. Consumers form a vital link between packaging suppliers, brands, retailers and the waste management industry but, in order for them to do the right thing, the message must be simple and straightforward.
Our research shows that consumers are increasingly turning to packaging for guidance, information and direction on sustainability. For example, in our most recent survey, 70 per cent of those questioned said they prefer to buy a brand that shows clear labelling on how to recycle. Almost all – 95 per cent of respondents – showed a belief that packaging should feature recycling labels.
OPRL has been supporting businesses to provide clear recycling labels for more than 15 years. Above all else, our experience shows that consistency is crucial. With the implementation of Extended Producer Responsibility (pEPR) for Packaging, all household packaging will require a ‘Recycle/Do not recycle’ label in the same format that OPRL supplies to its members. This will help to eliminate any confusion and aims to kick-start a nationwide uplift in the volumes of packaging sent for recycling.
Preparing for pEPR will be challenging for brands, but this is undoubtedly the direction of travel. Even without the regulatory demands, clear messaging and confidence in the accuracy of recycling claims go a long way to safeguarding reputations and building a positive relationship with consumers. But how are recyclability claims decided and what does the new legislation involve?
Why pEPR?
As governments and consumers become more aware of the impact of packaging on the environment – as well as the resource and carbon benefits of recycling – packaging EPR is being introduced around the globe. The detail varies from country to country, but the overall purpose is to drive up recycling rates and the quality of recyclate, in a way that values the materials we use.
We know that packaging is essential to protect the products we buy, but the goal is to encourage the redesign of packaging products to reduce the materials needed or to make them more recyclable.
Recycling can have a huge impact. It preserves habitats and resources and reduces carbon emissions. It also saves money. According to Lambeth Council in London, it is six times cheaper to dispose of recycled waste than black bag waste. As pEPR places responsibility for the costs of disposing of waste onto UK brands, recycling makes sense from all directions.
What will pEPR mean for my brand?
Data reporting for Packaging EPR has already started, with the first fees due in 2025. This means that any brands which are not already registered must find out whether they are obligated and start to collect the necessary data. By 1 April 2027, every product placed on the market that is destined for the household bin must feature the correct recycling instructions.
Mandatory labelling for recyclability
Mandatory labelling plays a critical role in the changes arriving with pEPR. Under the new regulations, all products will display the recycling swoosh that is currently only in use by OPRL members, with a simple instruction to ‘recycle’ or ‘do not recycle’. The rules apply to any packaging that is ultimately destined for the household bin.
Before businesses can jump ahead and plan for new labels, they need to know whether their packaging is recyclable. This may sound straightforward, but assessing recyclability is a complex process that encompasses the entire supply chain.
Over the years, we have found that there is far more to labelling than the final label. The outcome may be a simple label, but the detail and evaluation behind it are complex and nuanced. In order to make our decisions on whether to award a recycling label, OPRL uses evidence-based assessments from an independent panel of representatives from the packaging, brand and waste management sectors. To qualify as recyclable, packaging must be collected, sorted, processed and sold as recyclate for use in new packaging or products.
So far, OPRL has been the only organisation awarding independent assessments but, under the new legislation, Defra will provide definitive guidance. It has committed to giving businesses two years to plan ahead, which means that full guidance on which materials are recyclable would need to be available by 31 March 2025.
We recommend that businesses begin preparations as early as possible – we know that updating artwork, managing print runs and controlling stock levels takes time. Some will find it more straightforward than others – some packaging designs remain the same for years; others change year-on-year.
Common queries
OPRL members include eight of the 10 largest grocery brands, as well as numerous smaller businesses. A recent poll taken during one of our webinars showed that for many of our members, expertise in legislation represents the largest opportunity for improvement. We also asked about key sustainability packaging goals; not surprisingly, these also tied in with the government’s packaging reforms. Increasing recycled content, for example, figured highly, as did plastic reduction.
With pEPR on the horizon, we have seen a marked increase in queries. These range from, ‘How do you calculate a 25cm2 surface area?’ and ‘What is the largest face on a sphere?’, to ‘What are the cost implications of recyclability assessments?’. In some instances, we may need to have to change our labelling rules in order to fit in with the official recyclability assessment methodology (RAM). As a result, OPRL members would need to change their labels, so we will be working to communicate those changes to our members in a timely manner, as soon as the specifications are available.
Conclusion
There is no avoiding the fact that the scale of change under pEPR is enormous, but we need to keep in mind that this is the first stage of an evolving system. Every part of the value chain has different needs and requirements, so we need to embrace the fact that we are not going to have a perfect solution that will work immediately for everyone. One of the most positive aspects so far is the increase in communication and understanding up and down the chain; we need to capitalise on that, and we will, eventually, see a system we can all be proud of.
EPR labelling, at a glance…
Under pEPR, brands will become responsible for the full net costs of disposing of household packaging at the end of its life.
As well as reporting twice a year on the packaging placed on the market, businesses must ensure that each packaging product is labelled with a standardised ‘Recycle/Do not recycle’ label which follows the format of the current OPRL label. Recyclability will be established by an official Recyclability Assessment Methodology (RAM).
Key dates include:
- 1 January 2025: pEPR regulations come into effect.
- 31 March 2026: Simpler Recycling phase 1 – local authorities in England must collect the same set of packaging materials from households.
- 31 March 2027: Simpler Recycling phase 2 – Launch of local authority household collections for some flexible plastics.
- 1 April 2027: Mandatory labelling is required for all new household packaging placed on market, with the exception of those items collected through a deposit return scheme (DRS).
Jude Allan is the Interim MD at OPRL
She started out as a packaging technologist at Mars before taking the experience of brand owner into the world of a packaging design agency. For almost 20 years, she championed and led the production and creative operations at jonesknowlesrtichie as it grew from London based agency to global design business.
