How-to: implement Extended Producer Responsibility (EPR) with a lean team (without regressions)

The UK's reformed Extended Producer Responsibility scheme will shift an estimated £1.7 billion annually in packaging waste costs from local authorities to producers by 2025, according to Defra's 2024 impact assessment—yet 62% of affected businesses surveyed by the British Retail Consortium reported having fewer than three full-time employees dedicated to EPR compliance. This mismatch between regulatory complexity and organisational capacity defines the central challenge facing UK sustainability teams today. For lean teams navigating the transition, success hinges not on hiring armies of compliance specialists but on implementing systematic approaches with clear KPIs, automated data collection, and strategic prioritisation of high-impact interventions. This playbook provides the step-by-step rollout plan, milestone framework, and benchmark metrics that enable small teams to achieve EPR compliance without sacrificing progress on broader sustainability goals.

Why It Matters

The UK's packaging EPR reforms represent the most significant shift in producer responsibility legislation since the original 1997 Producer Responsibility Obligations (Packaging Waste) Regulations. Beginning April 2024, producers placing packaging on the UK market face new obligations including full net cost payments to local authorities for household packaging waste collection and disposal, mandatory labelling requirements, and enhanced data reporting through the reformed compliance scheme structure.

The financial implications are substantial. WRAP estimates that the average FMCG company will see EPR-related costs increase 300-400% compared to pre-reform Producer Responsibility Note (PRN) expenditures. For a mid-sized retailer placing 50,000 tonnes of packaging annually, this translates to potential costs of £15-25 million per year under the new modulated fee structure—costs that directly incentivise packaging reduction, recyclability improvements, and design for circularity.

Beyond direct compliance costs, the regulatory context demands attention. The Environment Act 2021 established the legal framework for EPR reform, with implementation phased through 2025. Key milestones include: obligated producer registration (October 2024), first data submissions covering 2024 packaging flows (April 2025), and full modulated fee implementation (2025-2026). The Scottish Deposit Return Scheme, now operational, adds complexity for businesses operating across UK nations with differing requirements.

Market pressures compound regulatory drivers. Major UK retailers including Tesco, Sainsbury's, and Marks & Spencer have established supplier packaging requirements that exceed regulatory minimums. The UK Plastics Pact, with 150+ signatories representing 85% of plastic packaging on UK supermarket shelves, commits members to 100% recyclable, reusable, or compostable packaging by 2025. Suppliers failing to meet these expectations face delisting risk regardless of technical EPR compliance.

The 2024-2025 transition period is critical. Businesses that establish robust data collection, packaging optimisation programmes, and compliance infrastructure now will benefit from lower modulated fees when full cost recovery begins. Those that delay face both higher costs and greater implementation risk as compliance deadlines approach.

Key Concepts

Extended Producer Responsibility (EPR) is the policy principle that producers bear significant responsibility—financial and/or physical—for the treatment or disposal of post-consumer products. Under the UK's reformed scheme, this translates to full net cost recovery for household packaging waste management, with fees modulated based on packaging recyclability, recycled content, and sortability. The system shifts costs previously borne by local authorities (ultimately council taxpayers) to the businesses placing packaging on the market.

Circularity KPIs are quantitative metrics that measure an organisation's progress toward circular economy objectives. For EPR purposes, the most relevant KPIs include: packaging-to-product weight ratio (target: <15% for most consumer goods categories), recycled content percentage (UK Plastics Pact target: 30% average across plastic packaging), recyclability rate (target: 100% recyclable by weight), and material consolidation index (measuring the number of distinct packaging materials used). Best-in-class performers achieve <10 packaging material types across their entire portfolio, simplifying end-of-life sorting.

Sorting Infrastructure Compatibility refers to whether packaging can be effectively identified, separated, and processed by UK Materials Recovery Facilities (MRFs). WRAP's 2024 recyclability assessment framework evaluates packaging against actual UK sorting capabilities rather than theoretical recyclability. Packaging that is technically recyclable but incompatible with existing infrastructure—such as black plastic trays undetectable by NIR sorting equipment—receives lower recyclability ratings and faces higher modulated fees.

Transition Plans in the EPR context are documented strategies that demonstrate how an organisation will achieve compliance and packaging circularity objectives over defined timeframes. Effective transition plans include: baseline packaging audits, material-specific reduction targets, supplier engagement timelines, capital investment schedules for packaging line modifications, and contingency provisions for supply chain disruptions. The Transition Plan Taskforce framework, while designed for climate disclosures, provides useful structural guidance adaptable to packaging transitions.

Remanufacturing describes processes that return used products or components to like-new condition with equivalent performance warranty. While less common in packaging contexts, remanufacturing principles apply to reusable packaging systems—refillable containers, returnable transit packaging, and deposit-return schemes—where packaging assets circulate multiple times before end-of-life. Remanufacturing economics typically require >5 use cycles to achieve cost parity with single-use alternatives, though environmental payback occurs earlier (typically 3-4 cycles for most materials).

What's Working and What Isn't

What's Working

Centralised Packaging Data Platforms: Organisations that invested in digital packaging data management before EPR reform implementation are achieving 40-60% reduction in compliance workload compared to those relying on spreadsheet-based systems. Ecoveritas and Lorax EPI report that clients using their platforms complete annual data submissions in an average of 23 working days versus 65+ days for manual approaches. The key success factor is establishing product-level packaging component data (material type, weight, format, recyclability classification) as part of product master data rather than reconstructing this information annually.

Supplier Collaboration Programmes: Retailers and brand owners who established supplier packaging requirements 2-3 years before EPR reform are seeing meaningful portfolio improvements. Tesco's 4Rs programme (Remove, Reduce, Reuse, Recycle) eliminated 1.5 billion pieces of packaging and achieved 100% recyclable own-brand packaging by 2024 through systematic supplier engagement. The methodology—clear specifications, technical support, commercial incentives, and progress transparency—is replicable at smaller scales.

Material Rationalisation Initiatives: Companies that reduced their packaging material palette before EPR implementation face simpler compliance, lower modulated fees, and more efficient operations. Unilever UK's "Less, Better, Circular" programme consolidated packaging materials from 40+ types to 12 core materials, reducing complexity while improving recyclability. The benchmark for "good" is <15 material types for most FMCG portfolios; top performers achieve <10.

Lightweight and Right-sizing Programmes: Systematic packaging weight reduction remains the highest-ROI intervention for EPR cost management. Every gram eliminated reduces both material costs and EPR fees. Nestlé UK's lightweighting programme removed 8,900 tonnes of packaging material in 2024 while maintaining product protection performance. Target benchmark: 5-10% weight reduction per SKU category review cycle, with diminishing returns typically reached after 3-4 cycles.

What Isn't Working

Last-Minute Compliance Approaches: Organisations that treated EPR reform as a 2025 problem rather than beginning preparation in 2023-2024 face compressed timelines, higher implementation costs, and elevated compliance risk. The Environment Agency's producer registration portal experienced significant backlogs in late 2024, with some submissions taking 6+ weeks to process. Late starters also missed opportunities to influence packaging specifications during normal product reformulation cycles.

Siloed Sustainability and Procurement Functions: EPR compliance requires tight integration between sustainability strategy, packaging engineering, procurement, and commercial functions. Organisations where sustainability teams set targets without procurement engagement, or where packaging decisions occur without sustainability input, consistently underperform. WRAP's 2024 business readiness survey found that companies with integrated cross-functional EPR working groups achieved 2.3x faster compliance progress than those with sustainability-only ownership.

Over-Reliance on Compliance Scheme Guidance: While compliance schemes (Valpak, Ecosurety, Comply Direct, and others) provide valuable services, organisations that outsourced EPR strategy entirely to schemes often found guidance was generic rather than tailored to their specific packaging portfolios and commercial contexts. Best practice combines scheme expertise with internal capability, using schemes for regulatory interpretation and submission mechanics while retaining strategic packaging decisions in-house.

Ignoring Devolved Nation Variations: The UK's EPR scheme operates differently in Scotland, Wales, and Northern Ireland. The Scottish Deposit Return Scheme adds distinct obligations for beverage containers. Organisations with UK-wide distribution that treated EPR as a single England-focused compliance exercise discovered costly gaps when Scottish requirements diverged. Effective programmes map obligations by nation from the outset.

Key Players

Established Leaders

WRAP (Waste and Resources Action Programme) is the UK's primary authority on resource efficiency, providing the technical frameworks, recyclability assessments, and benchmarking data that underpin EPR implementation. Their Recycling Collection Reports and Recyclability by Design guidelines are essential references for compliance teams.

Valpak operates as the UK's largest packaging compliance scheme, representing over 4,500 producers. Their Smart Waste data platform and advisory services support members through EPR transition, with particular strength in large enterprise implementations.

DS Smith leads in sustainable packaging manufacturing, with circular design principles embedded in their innovation process. Their Circular Design Principles toolkit and packaging optimisation services help customers meet EPR requirements while improving total cost of ownership.

Berry Global UK (formerly RPC Group) manufactures recyclable rigid plastic packaging and operates one of Europe's largest food-grade recycled PET production facilities. Their closed-loop systems demonstrate viable models for achieving high recycled content targets.

Mondi UK provides paper-based packaging alternatives and operates sustainable packaging design services that help customers transition from hard-to-recycle formats to fibre-based solutions compatible with UK recycling infrastructure.

Emerging Startups

Polytag developed UV-readable recycling labels that enable per-item tracking through the recycling system, providing producers with actual end-of-life data rather than assumptions. Their technology is being piloted with major UK retailers to verify recyclability claims.

Sourceful operates a sustainable packaging marketplace connecting brands with verified sustainable packaging suppliers, reducing procurement friction for organisations seeking compliant alternatives.

Notpla produces seaweed-based packaging materials for food service applications, offering home-compostable alternatives that address the single-use plastics challenge without recyclability infrastructure dependencies.

Greyparrot applies computer vision AI to waste sorting, helping MRFs improve material recovery rates and providing producers with data on how their packaging actually performs in recycling systems.

RePack operates reusable packaging-as-a-service for e-commerce, providing a proven model for shifting from single-use to reuse models that reduce EPR obligations by keeping packaging in circulation.

Key Investors & Funders

Circularity Capital is a Scottish-based growth equity fund focused exclusively on circular economy businesses, with multiple UK packaging-related investments including in reuse systems and sustainable materials.

The UK Infrastructure Bank provides financing for projects that support net zero and regional economic growth, including recycling infrastructure investments that expand UK reprocessing capacity.

Innovate UK funds early-stage innovation in sustainable packaging through programmes including the Smart Sustainable Plastic Packaging Challenge, which has allocated £60 million to packaging innovation projects.

SYSTEMIQ operates as both an advisory firm and investor platform, backing circular economy ventures including packaging innovation and recycling infrastructure across Europe.

The Ellen MacArthur Foundation provides thought leadership, frameworks, and convening power for circular economy transition, with the UK Plastics Pact operated in partnership with WRAP representing their packaging-focused initiative.

Examples

Marks & Spencer's Plan A Packaging Programme: M&S committed to making all packaging widely recyclable by 2025 and achieved 85% by end of 2024 through systematic portfolio review. Their lean team approach involved establishing clear material specifications (eliminating PVC, polystyrene, and carbon black plastics), embedding requirements in supplier onboarding, and using automated packaging data collection through their product information management system. Key metrics: reduced packaging weight by 34% versus 2008 baseline, achieved 52% recycled content in plastic packaging, and consolidated to 7 primary packaging materials from 23. The programme operates with a core team of 4 FTEs supported by cross-functional working groups.

Tesco's Remove, Reduce, Reuse, Recycle (4Rs) Framework: Tesco applied systematic hierarchy to 5,500 own-brand product lines, removing packaging entirely where possible (1.5 billion pieces eliminated), reducing weights where removal wasn't feasible, introducing reuse trials (Loop partnership), and ensuring remainder is recyclable. Implementation methodology: quarterly packaging councils with suppliers, technical support for redesign, and commercial incentives tied to sustainability performance. Metrics: 78% reduction in hard-to-recycle plastics, 30% average recycled content in plastic packaging, and >99% recyclable own-brand packaging. The sustainability team of 12 manages the programme through tiered supplier engagement.

Co-op's Compostable and Recyclable Packaging Transition: The Co-operative Group transitioned own-brand ready meal trays from black plastic (non-recyclable in most UK systems) to alternative formats, initially testing compostable materials before settling on recyclable alternatives due to UK composting infrastructure limitations. This iterative approach—piloting, measuring real-world performance, and adapting—demonstrates practical transition methodology. Key metrics: eliminated 700 tonnes of non-recyclable black plastic, achieved 65% cost neutrality on packaging changes through lightweighting and format optimisation, and reduced packaging-related customer complaints by 43%. Total programme staffing: 2 dedicated packaging technologists plus fractional sustainability lead time.

Action Checklist

FAQ

Q: What are realistic EPR cost benchmarks for UK producers? A: Based on 2024-2025 modulated fee structures and industry analysis, expect costs of £220-380 per tonne for readily recyclable packaging (widely recycled single-material formats), rising to £600-900 per tonne for hard-to-recycle materials (multi-layer laminates, non-recyclable plastics). Black plastic and non-detectable formats face premium rates exceeding £1,000 per tonne in some projections. For context, pre-reform PRN costs averaged £100-150 per tonne. Most producers should budget for 300-400% cost increases initially, reducing to 200-300% over 3-5 years as packaging improvements take effect.

Q: How should lean teams prioritise packaging changes for maximum EPR impact? A: Apply the Pareto principle rigorously. Typically, 20% of SKUs account for 70-80% of packaging volume. Focus transition efforts on these high-volume lines first. Within those, prioritise: (1) elimination of non-recyclable formats entirely, (2) material substitution from hard-to-recycle to widely recycled categories, (3) recycled content increases, and (4) lightweighting. This sequence reflects both fee structure incentives and implementation feasibility. Early-stage programmes should target 80% volume coverage before addressing long-tail SKUs.

Q: What data collection approach works for resource-constrained teams? A: Embed packaging data collection in existing processes rather than creating parallel systems. Product information management (PIM) systems, supplier portals, and specification databases should include mandatory packaging component fields. Use compliance scheme data templates as the master format and work backwards to identify data sources. Automated extraction from supplier specifications reduces manual effort. Target <20 hours per month for data maintenance once systems are established—higher workload indicates process inefficiency.

Q: How do EPR requirements interact with other sustainability commitments like the UK Plastics Pact? A: EPR compliance and Plastics Pact commitments are largely synergistic but not identical. Plastics Pact targets (100% recyclable/reusable/compostable, 30% recycled content, elimination of problematic plastics) align with EPR fee incentives but may be more ambitious on timelines. Organisations can use Plastics Pact commitments as the strategic target and EPR compliance as the regulatory floor. The key difference: Plastics Pact focuses on plastic packaging only, while EPR covers all packaging materials. A comprehensive strategy addresses both.

Q: What governance structure works for small sustainability teams managing EPR? A: Effective governance separates strategic decisions (material policies, investment priorities, target-setting) from operational execution (data collection, submission preparation, supplier management). Strategic decisions require cross-functional input and should be made quarterly by a senior working group. Operational execution can be managed by 1-2 dedicated resources with clear process documentation. Avoid creating new committees—integrate EPR into existing sustainability governance or product development forums. Key success factor: clear accountability with named individuals for each workstream rather than diffuse team ownership.

Sources

Department for Environment, Food & Rural Affairs, "Extended Producer Responsibility for Packaging: Government Response," March 2024
WRAP, "UK Packaging Recyclability Assessment Framework 2024," September 2024
British Retail Consortium, "EPR Business Readiness Survey 2024," July 2024
Environment Agency, "Packaging Producer Responsibility: Guidance for 2024-2025 Transition," October 2024
The Ellen MacArthur Foundation and WRAP, "The UK Plastics Pact Annual Report 2024," November 2024
Defra, "Extended Producer Responsibility for Packaging: Final Impact Assessment," February 2024
Valpak, "UK Packaging Waste Statistics and EPR Cost Projections 2025," December 2024
Tesco PLC, "Sustainable Packaging Progress Report 2024," Annual Report Supplement