NGO

Tracking who is watering down packaging regulations and why

Policy Campaigns Manager·Environmental NGO

Project:Extended Producer Responsibility — Packaging Reform

The Challenge

Extended Producer Responsibility for packaging is being phased in, but industry lobbying has already delayed and softened elements of the regime. The campaign team needs to track which amendments are being pushed, which ministers are listening to industry, and where the political pressure points are.

The Conversation

Extended Producer Responsibility — Packaging Reform — Chat

Has the EPR for packaging regime been weakened since it was first announced? What changed?

Significantly weakened in places. The producer fee structure has been revised twice — initially the modulated fees were designed to make unrecyclable packaging very expensive, but industry lobbied successfully to soften the differentiation between recyclable and hard-to-recycle materials. The glass exemption for small producers was also expanded beyond the original scope. DEFRA has framed these as technical adjustments but the effect is lower financial incentive to switch to genuinely recyclable formats.

Who are the key industry voices lobbying against the stricter version? I want to know who we need to counter.

The British Plastics Federation has been the most active — they have good access to DEFRA officials and have submitted detailed technical responses to every consultation. The Food and Drink Federation has focused on the cost burden argument, particularly for SMEs. Retailer lobby groups (BRC) have pushed back on the data reporting requirements. On the other side, WRAP and the Ellen MacArthur Foundation have been your natural allies — both have published research challenging the industry's cost estimates.

Deep Dive Output

high confidence

Overview

Extended Producer Responsibility for packaging commenced in October 2023 for data reporting, with fee payments beginning in 2025. The scheme has been materially amended since original consultation — modulated fee differentials have been reduced, reporting thresholds adjusted, and implementation timelines slipped. DEFRA's position has shifted toward accommodation of industry concerns under cost-of-living political pressure. Environmental groups have had limited success in the formal consultation process but some impact through media coverage.

Relevant Legislation

Environment Act 2021 — EPR provisions

In force · Royal Assent

Packaging Waste (Data Reporting) Regulations 2023

In force · Secondary legislation

Producer Responsibility Obligations (Packaging) Regulations 2024

In force · Secondary legislation

Key Stakeholders

WRAP

Waste and Resources Action Programme

Supporting stricter modulated fees; has published evidence challenging industry cost claims

British Plastics Federation

Industry trade body

Lobbying for lower fee differentials and longer implementation timelines

Mary Creagh

Minister for Nature

Publicly committed to circular economy but has accepted several industry-backed amendments

Ellen MacArthur Foundation

Circular economy NGO

Providing technical counter-evidence to industry lobbying on recyclability definitions

Media Framing

Guardian and Observer coverage has been sympathetic to environmental position. Trade press (Packaging News, ENDS Report) provides detailed technical coverage. Government press releases emphasise ambition without covering dilutions. Industry framing of SME burden has been effective in mainstream media.

Entity Graph

WRAP

Environmental body

British Plastics Federation

Industry lobby

Mary Creagh

Minister for Nature

Ellen MacArthur Foundation

Campaign NGO

What They Track

EPR packaging fee consultationsDEFRA secondary legislationBritish Plastics Federation submissionsWRAP research publications

← PreviousModelling returns against a shifting incentive landscape Next →Running four client briefs in parallel without doubling headcount

Get started

This could be your project.

Set up a project, describe your brief, and start asking. Your first deep dive takes about 90 seconds.

Try it free