Plastic bottles
Published date: 11 October 2023

NLWA highlights impracticalities in proposed EPR legislation

NLWA has again called on the government to ensure clarity and practicality are embedded in national waste management policy. These calls came as part of NLWA’s response to the government’s consultation on the proposed draft producer responsibility obligations regulations for extended producer responsibility (EPR).

NLWA Chair, Cllr Clyde Loakes, said: “We’ve always been big advocates of EPR as a policy. There’s an urgent need to move the burden (and cost) of waste management back on producers, creating an economic incentive for them to reduce waste and adopt more sustainable design processes. But the proposed scheme lacks clarity about how the policy will apply, and there’s little consideration about how this will function at the local government level.

“We disagree with the exclusion of business waste from the legislation. With no incentive for industry to improve its standards on business waste, owing to its exclusion from the scheme, this will continue to be costly for local authorities to process. Local authorities know from first-hand experience that household waste streams frequently contain business waste. This needs to be factored into considerations about how local authorities will recover costs.

“In the absence of certainty about the deposit return scheme (DRS) implementation date, provisions need to be made for how this waste stream will be dealt with in the meantime. The EPR legislation should make clear that it will cover all drink containers currently outlined under the Deposit Return Scheme until this scheme is up and running.

“We are also concerned by the proposal that the amount local authorities will receive will depend on how ‘effective’ or ‘efficient’ their services are. The government has previously proposed grouping authorities together and comparing their efficiency and effectiveness. However, it is hard to compare local authorities directly, as most bear significant differences to others. Even within London, the management of waste has to be tailored according to local needs; the differences are only magnified when looking at this on a national level. With such different circumstances experienced by each local authority, it is impossible to apply a single, uniform measure of effectiveness across them all.

“We would welcome any opportunity to discuss this feedback and potential solutions with the government, to ensure this crucial legislation is implemented in the most effective way for British taxpayers.”

Read NLWA's full response: NLWA response to Extended Producer Responsibility (EPR) regulations consultation.