Modulated Fees for Extended Producer Responsibility 

Launch of stakeholder engagement  

 To ensure EPR fee structures fit with the needs of industry and recognise real life packaging impacts on the ground, the four nations are jointly launching a set of engagement activities before fees for packaging are agreed within the new EPR scheme.

EPR fees to reflect sustainability of packaging materials   

From 2025/2026 onwards, EPR fees will be adjusted (modulated) to incentivise businesses to use materials with a lower environmental impact. This will mean that more recyclable packaging in each material type will be priced at proportionally less per tonne than less recyclable packaging in the same material type.

The implementation of a modulated fee structure will encourage businesses to use materials that are recyclable. Our vision is that by 2030, the packaging supply chain will be optimised, to maximise recycling rates and material quality. This will in turn minimise the environmental impact of packaging waste. Our ultimate goal is for all packaging to be recyclable by 2030 where recyclable packaging options (or re-use systems) are available.   

The use of a modulated fee structure is an approach that is widely used across leading international EPR schemes.

Fees will be modulated within each material group.

For example, an increased fee for one type of plastic will lead to a decrease in the fees for other types of plastic. Fees may also be modulated between material groups (e.g. an increased fee for plastic leading to a decreased fee for paper and card), but only where necessary to avoid perverse environmental outcomes. The scale of the adjustments will initially be set by the four nations, and later by the Scheme Administrator. Modulation will be based on a material’s recyclability in the first year, with the possibility to add further environmental factors in the future.   

Our aim is to publish the modulation factors by the end of 2023 to give producers time to make preparations. We recognise the central role producers and their representative organisations need to play in establishing this pricing mechanism. Initial engagement has begun to establish the precise responsibilities that they and other parts of the waste value chain will play. Further engagement will be required, and we expect this will be via:  

Focus groups - we will be scheduling workshops with stakeholders from across the value chain on modulation topics most relevant to them, their EPR for packaging interests and responsibilities.   

Stakeholder forums - we are keen to engage across the waste value chain and we will be presenting at the CPR Business Readiness Forum (BRF) on Tuesday 30 May at 10am (Join here). If you cannot attend this session there will be opportunities at future BRFs to provide input.   

Survey - to provide another avenue for input into modulated fees, we will be launching a survey. We are keen to hear from as many stakeholders as possible, please do look out for the survey in a future newsletter.      

The aim of this engagement is to:  

• Seek views on materials with lower recyclability that could be given an increased fee in the first year of modulation 
• Derive criteria to more robustly assess which materials to modulate (both in the first year and in future years), and by how much, to inform further analysis
• Work closely with stakeholders to agree a vision statement for modulated fees, to be published by Autumn 2023
• Invite representatives from across the value chain to take part, including large and small producers, waste management companies, material recovery facilities, trade associations, environmental groups and local authority networks.   

Please join the Business Readiness Forum on 30 May at 10am to hear more about modulated fees.