(CGN 10) EXTENDED PRODUCER RESPONSIBILITY

CGN 10 takes on one of the biggest changes currently reshaping the waste and packaging sector - Extended Producer Responsibility (EPR).

For years, packaging producers could place almost anything onto the market with very little financial connection to what happened afterwards. If it was difficult to recycle, contaminated the recycling stream, or simply ended up being burned or buried, the costs usually landed elsewhere - councils, taxpayers, waste contractors and ultimately the environment itself. EPR is supposed to change that.

In this Circular Guidance Note, we explore:

• why EPR matters
• how the RAM (Recyclability Assessment Methodology) could become one of the UK’s most important waste policy tools
• why procurement decisions now carry long-term financial consequences
• how “cheap packaging” may become expensive packaging
• why some producers may simply pass additional costs straight back to customers instead of redesigning poor packaging

We also touch on the increasingly controversial debate surrounding glass packaging, along with comparisons between the UK’s approach and the far more ambitious direction being taken under the EU’s Circular Economy Action Plan (CEAP) and Packaging & Packaging Waste Regulation (PPWR).

Importantly, this CGN is not anti-EPR. In fact, parts of the framework, particularly RAM may finally begin linking packaging design to real-world recyclability and real-world financial consequences which, being honest, the industry has needed for a very long time.

More than ever, with the introduction of pEPR, good recycling starts in procurement. CGN 09 - link - more like this - (pEPR) - link - more like this (CEAP) - link

CGN Disclaimer & Community Review

As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.

I have always believed that in waste management, getting it right matters more than pretending to already know everything.