The focus for the scheme administrator overseeing extended producer responsibility (EPR) must be local authority collection funding, communication campaigns and strategic oversight, Ecosurety says.
The compliance specialist published its responses to the government’s consultations on EPR and the deposit return scheme (DRS) on 21 May to “encourage as many stakeholders as possible to respond”.
Robbie Staniforth, Ecosurety’s head of innovation and policy, said: “We are releasing our official responses to government ahead of the deadline so that our compliance scheme members and wider stakeholders can access our views when considering their own response.
“We believe the new system must be balanced and provide a positive direction of travel for many years to come. We encourage as many stakeholders to individually respond to government as possible.”
Ecosurety says it will publish its response to the government’s delayed consultation on consistency in recycling collections before it closes on 4 July.
Ecosurety’s head of partnerships Jon Brookes spoke to letsrecycle.com last week to urge all stakeholders to respond to the consultations (see letsrecycle.com story).
He said stakeholders could base responses on Ecosurety’s if required, and focus on questions which are most relevant to them.
The deadline for responses to the consultations on EPR and the DRS is 4 June.
EPR
The government launched its consultation on EPR on 24 March (see letsrecycle.com story).
Ecosurety says the EPR consultation will have the biggest impact on packaging in the UK of all the changes pursued by the government. The biggest challenge will be the creation of a new scheme administrator, the compliance specialist said in its response.
The scheme administrator should look to use modulated fees to incentivise the adoption of reuse and refill packaging systems once the system is established and fully operational, Ecosurety says.
The compliance specialist believes all local authorities should collect plastic films by 2026/2027.
More research needs to be done into the potential harmful effects of compostable and biodegradable plastic packaging, Ecosurety says, after which modulated fees can be adjusted “accordingly”.
And, the compliance specialist said it believed the scheme administrator would not have sufficient time to mobilise to make payments to local authorities from October 2023 if it was appointed in January 2023 as proposed.
DRS
The government’s consultation on the DRS was also launched on 24 March (see letsrecycle.com story).
In its consultation response Ecosurety says it remains “broadly supportive” of implementing a DRS, but clarifications are needed.
The compliance specialist favours the ‘all in’ option to align England with Scotland and Wales. It says the size of the containers collected via the scheme should not exceed 3L, as is the case in Scotland.
If an ‘on the go’ system is chosen, multi-pack containers should not be excluded from the scheme, Ecosurety says. Instead, a variable deposit level should be applied.
It suggests the minimum deposit level should be 10p and the maximum 50p. A high level of unredeemed deposits funding the scheme would be problematic, Ecosurety says, because it would signal the DRS was not collecting the desired material.
Almost all retailers selling in-scope drinks containers should be obligated to host a return point, Ecosurety says, though there should be a narrow exemption for retailers with very little floor space.
Related links
Ecosurety consultation responses
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Source: letsrecycle.com Packaging