With an array of regulatory and fiscal interventions coming rapidly down the track and increasing NGO and public pressure to ‘get packaging right’, the spotlight is sharply focused on sustainable packaging.
The scale of potential monetary and reputational costs makes this a strategic issue for FMCG Boards. But is government enabling businesses to prepare?
The Plastic Tax takes effect in April 2022 so securing reliable supplies of post-consumer recyclate to meet the 30 percent content requirement is an immediate priority. Capturing more used plastics and expanding UK processing beyond the current 10 percent will be essential, practically and reputationally.
Less clear and more complex regulatory measures on Extended Producer Responsibility (EPR) will result from the Environment Bill, still staggering through Parliament. Recyclability and ‘litterability’ are both proposed as factors driving a £2.7bn bonus/malus fee system, with little clarity on what will score well. Taking effect in ‘early 2024’, the clock is ticking on range reviews to minimise liabilities. EPR will also introduce mandatory recycling labelling, with Defra’s preferred approach a loosely regulated market with multiple ‘approved’ designs, likely to exacerbate consumer confusion rather than deliver the ‘clear and consistent labelling’ promised.
The potential for three or even four different – and differing – Deposit Return Schemes (DRS) across the UK and RoI presents massive headaches for the beverage sector. The Scottish scheme is already decided and proceeding quickly. Coming up fast on the rails is an Irish scheme. England and Northern Ireland propose a joint approach which Wales may back and which may or may not align with Scotland and/or Ireland. In practical terms two schemes, GB and the island of Ireland, would be easier to manage, particularly on fraud. But that’s not how politics works. Proposals for labelling remain unclear and will fall under separate legislation from non-beverage packaging.
OPRL has provided the only evidence-based UK labelling scheme since 2009. Our 640 members include 95 percent of groceries multiple retailing and 93 of the Top 100 groceries brands, accounting for more than £83bn annual sales, and membership is growing fast in other sectors. Consumer insight shows our labels are recognised by 4 in 5 consumers, with 95 percent confident they understand our binary ‘Recycle’ and ‘Don’t Recycle’ labels. Consumers repeatedly tell us a multiplicity of labels confuses them.
We’re calling on government to put consumers at the heart of labelling with a single label design delivered by competing providers. A single system encompassing all recycling – at home, at work or on-the-go, via council collections, DRS or front-of-store – is the only way to deliver clarity for consumers and cost-effective services for obligated producers.
Our 12 years’ experience in defining recyclability also means we understand how to build the evidence base and decision framework to ensure a fair system sufficiently agile to assess innovative packaging materials and designs. We believe we can help develop the EPR framework at pace to enable businesses to prepare now for 2024, delivering cost savings and environmental benefits. We’ll be working with our members to do just that.
• Jane Bevis is the Executive Chair at OPRL LTD
