Packaging - extended producer responsibility: full business and regulatory impact assessment (BRIA)
Final business and regulatory impact assessment (BRIA) for the reform of the packaging producer responsibility regulations, which follows previously published partial BRIAs.
Footnotes
6. The Producer Responsibility Obligations (Packaging Waste) Regulations 2007
7. Obligated businesses are those who place more than 50 tonnes of packaging and have a turnover of more than £2 million per year.
8. Plastic bottles: Turning Back the Plastic Tide, paragraph 38.
9. Consultation on reforming the UK packaging producer responsibility system 2019
10. Consultation on Extended Producer Responsibility for Packaging 2021
13. Note that the £1.2bn includes c. £100m for managing packaging disposed of in street bins. Along with the other UK governments, we intend to bring forward legislation to address this element of packaging EPR at a later date, to be in force by 2026.
15. Explore the National Outcomes - Scottish Government
16. Climate Change (Scotland) Act 2009
17. Climate Change (Emissions Reduction Targets) (Scotland) Act 2009
18. Securing a green recovery on a path to net zero: climate change plan 2018-2032 - update
19. The 17 goals, United Nations
20. Making Things Last: a circular economy strategy for Scotland
21. Scotland's Zero Waste Plan - Scottish Government
22. Safeguarding Scotland's resources: bueprint for a more resource-efficient and circular economy
23. Securing a green recovery on a path to net zero: climate change plan 2018-2032 - update.
24. Scotland's Circular Economy and Waste Route Map to 2030 Consultation
25. Plastic Packaging Tax: steps to take - guidance
26. Directive (EU) 2018/852 of the European Parliament and the Council
27. Circular Economy Package policy statement
28. New EU rules to reduce, reuse and recycle packaging.
29. For example, our current analysis suggests that producer payments under the current regulations would equate to around 7-11% of the full next costs of municipal (household and household-like) packaging waste collection and end-of-life treatment.
30. While producers do pay a proportion of net cost of packaging collection through the PRN system, this is likely to be small. Producers do also likely already pay for a proportion of C&I and Non-Household Municipal (NHM) costs through backhaul and direct contracts with waste collectors, and as such Household packaging is a priority for inclusion in EPR. Government does not intend to extend packaging EPR fees to these sectors at the current time but will keep these under review once we have improved data on tonnages and costs.
31. Net of any income from the sale of these materials to the reprocessing and recycling sectors.
32. Consultation on reforming the UK packaging producer responsibility system - Summary July 2019
33. Packaging and packaging waste: introducing Extended Producer Responsibility - Consultation outcome
34. WRAP - PackFlow Refresh 2023 Reports
35. Valpak - PackFlow COVID-19 Report
36. Simpler Recycling in England - Final Impact Assessment May 2024
37. Scenarios for Adjusting the Extended Producer Responsibility De Minimis Threshold
38. The UK Plastics Pact is a collaborative initiative that aims to help create a circular economy for plastics. Its membership includes businesses from across the plastics value chain as well as UK governments and NGOs: WRAP the UK plastic pact
39. The World’s Top Online Marketplaces 2023
40. Environment Agency - National Packaging Waste Database
41. Based on discussion with WRAP
42. A Study on Two Approaches to Extended Producer Responsibility for Packaging
43. Population estimates for the UK, England, Wales, Scotland and Northern Ireland: mid-2023
44. Competition and Markets Authority (2015). Competition Impact Assessment.
46. Although it is recognised that these lines are often blurred such that brand owners may also be packaging manufacturers.
47. As pointed out in the Eunomia De Minimis report (Scenarios for Adjusting the Extended Producer Responsibility De Minimis Threshold) there are some turnover outliers in the NPWD database hence the median was seen as a more robust measure of the average.
48. NPWD data suggest there are around 500 producers under the category ‘Converter’: those converting raw material into packaging.
49. Elasticity of demand and supply refer to the extent that demand and supply change when the price of a good changes. If they are inelastic, when price changes the quantities demanded and supplied respond little. The cost pass through depends on the elasticity of demand relative to the elasticity of supply in the relative market. If the elasticity of demand is large relative to the elasticity of supply (i.e. demand reacts more to a change in price than supply) the pass-through rate will be low while if the elasticity of demand is small relative to the elasticity of supply (i.e. demand reacts less to a change in price than supply) the pass-through rate will be high. For a more in-depth explanation of the role elasticities play in cost pass through, see: RBB: Cost pass-through: theory, measurement and potential policy implications
50. Models of different market structures, the assumptions they make underpinning how prices are set, imply how firms will change prices in response to a change in cost and hence they will pin down a theoretical pass-through rate.
51. Market structures in economics refer to the characteristics of the market which determine the behaviour of firms within that market. Monopoly and perfect competition are two such market structures. Monopoly refers to where there is only 1 firm that sells the given good and as such this firm can decide the price at which it sells. Perfect competition refers a market where there are a very large number of firms and as such none have the ability to set the price at which they sell.
52. RBB: Cost pass-through: theory, measurement and potential policy implications
53. The total packaging EPR payment inflated to 2023 prices is £1.326bn without the addition of VAT and £1.592bn with its addition.
54. Families and households in the UK - Office for National Statistics
55. That is not to say that we assume consumers are not demand inelastic, rather that these price impacts are insignificant.
56. WRAP - National Household waste composition 2017
57. Waste Landfilled in Scotland and Waste Incinerated in Scotland: SEPA - Waste data for Scotland
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