The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024: RPC opinion (green-rated)
Regulatory Policy Committee’s opinion on Defra's Packaging extended producer responsibility IA
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The measure reforms existing regulations to introduce a full net cost recovery system that requires producers to pay the full costs of household packaging they place on the market.
The RPC considers the IA fit for purpose. Overall, the IA is well-structured, and the discussion of impacts are broken down by the key market players affected in the supply chain. The EANDCB correctly classifies the direct and indirect impacts and the evidence supporting the Small and Micro Business Assessment (SaMBA) is considered sufficient.
This measure is part of the wider set of government initiatives to tackle littering, increase recycling rates and to incentivise producers to take greater responsibility for the environmental impacts of their products. Other related initiatives include Simpler Recycling and the Deposit Return Scheme (DRS) for drinks containers, and the RPC has issued opinions on the IAs for these measures.
DEFRA consulted on these reforms in 2019 and 2021 and explains that the current IA updates the analysis from the previous IAs to reflect the final policy decision. The RPC previously opined on the 2022 IA for Reforming the UK Packaging Producer Responsibility System, issuing an opinion which rated the IA fit for purpose and validating an EANDCB of £1,206.8 million. Since then, the proposal has been updated, requiring a re-submission of the IA to the RPC. This IA updates the proposal, reducing the scope of pEPR by removing mandatory take back of cups, mandatory labelling and binned packaging waste payments from ‘on the go bins’ functions from the proposal. The IA has also updated the implementation date and input data used in the analysis. This updated IA estimates a reduced EANDCB of £1,082 million RPC-DEFRA-4343(4) 4 07/10/2024 (2019 prices; 2020 present value base year), with a net present value of -£161.4 million over a 10-year appraisal period. Most of the key impacts have been monetised and costs are estimated to be £11,803 million, mainly accounted for by the full net cost payments from packaging producers. Benefits are estimated to be £11,602 million, with savings to local authorities being the largest benefit.
The Impact Assessment has been published on legislation.gov - an accessible link can be found here.