Extended Producer Responsibility (EPR) was designed to shift packaging choices toward more recyclable materials—but the UK’s evolving framework may be sending the wrong price signals. While fee modulation is set to kick in next year, applying a traffic-light scale based on the Recyclability Assessment Methodology, industry analysis suggests it doesn’t always align with material performance in real recycling systems.
The crux of the issue lies in how the UK currently classifies recyclable materials. Paper-based packaging with more than 15% plastic content is automatically labeled non-recyclable, regardless of how it behaves during pulping or recovery. That threshold—a compositional definition rather than a functional one—can penalize fiber-based solutions that include thin coatings essential for performance, such as moisture barriers or sealability.
Meanwhile, certain forms of plastic, despite being harder to recycle in practice, may attract lower EPR fees. The result is a cost structure that could push brand owners toward packaging formats EPR was meant to discourage—undermining both innovation and sustainability progress.
This divergence has real financial implications. EPR now directly affects budgets and design decisions. Brands seeking to reduce plastic use may find themselves penalized for choosing technically recyclable fibre composites that fall foul of outdated percentage-based definitions.
Materials specialist Aquapak has highlighted how this fee framework risks incentivising the wrong choices. Its review argues that many fiber composites, including those with light barrier coatings, are processed effectively using the same infrastructure as standard paper. The added recovery effort is minimal—yet these materials face higher regulatory costs under EPR.
The issue isn’t limited to semantics. Some packaging formats, previously considered widely recyclable under earlier systems, are now being reclassified—not because they’ve changed, but because the definitions have. This puts brands in a difficult position: opt for a technically sound, recyclable paper-based option and pay more, or choose plastic and gain a cost advantage under current rules.
Aquapak proposes a shift toward performance-based assessment. Rather than assigning recyclability based on static material percentages, policymakers could focus on actual outcomes—such as fiber recovery rates, contamination levels, and compatibility with existing recycling infrastructure. This would give procurement and sustainability teams clearer, more science-based guidance.
As an example, Aquapak points to its own water-soluble Hydropol polymer—designed to integrate into current recycling systems without harming marine environments. But the larger message is not about a single product; it's about updating policy to match how modern materials are designed and function.
EPR has the potential to drive smarter, more circular packaging solutions. But for that to happen, its incentives must reflect practical recyclability—not assumptions baked into outdated thresholds.
