At Fero HQ on 1 October a panel from the WSTA, Bevica and Fero agreed that the rules on extended producer responsibility are still being written. The one thing drinks businesses can control is the quality of their packaging data.
Freddie Joosten, Associate Director of Sustainability at the WSTA, opened with a policy briefing on Extended Producer Responsibility (EPR) and the Deposit Return Scheme (DRS). It covered EPR complexities, what comes next for EPR, the role of Exchange for Change in DRS and the Welsh approach to DRS. A panel followed, moderated by Desmond Woods of Fero bringing together Claudio Martell, Product Director at Bevica, Francesca Hartley, Implementation Consultant at Bevica and Tamara Jordaki, Product Manager at Fero.
Fees still unknown
EPR moves the cost of collecting and recycling household packaging from councils to the businesses that put it on the market. The principle is simple. The practice is not. Joosten explained that the regulatory timeline left businesses exposed. Brands that sold packaging in January last year had to place it on the market long before regulators confirmed the final cost per tonne. Those 2025 volumes will be billed at Year 2 rates. Twenty months on, the cost still remains unknown.
PackUK, the body running the scheme, has since said it cannot set Year 2 fees until every producer’s data has been checked. Its operational plan points to notices of liability by the end of November 2026. Listed companies are expected to tell shareholders their costs in advance. With billing in its current state that is not possible. For a finance director that means carrying an accrual nobody has confirmed. The panel’s advice was to build assumptions into budgets and expect cost changes each and every year.
Glass is heavy so weight is what counts
Per tonne, the glass fee looks modest. The Year 1 base fee was £192 a tonne against £423 for plastic. A glass bottle weighs far more than its plastic equivalent. The variance in weight means the difference in rates is eaten up and has unintentionally incentivised a move away from glass.
Base fees are modulated on recyclability. Defra's illustrative Year 2 modulated figures for glass were £185 a tonne for green, £205 for amber and £245 for red. Around 91% of glass is classified green so most producers sit at the bottom of that range. Red is the one to watch. The multiplier on red-rated packaging rises from 1.2 this year to 1.6 in 2027/28 and 2.0 in 2028/29.
The evening captured the industry's worry. Fee structures could penalise glass and push producers toward other materials without considering the full lifecycle or benefits of glass.
Cork is red so ratings matter
Ratings come from the Recyclability Assessment Methodology. Where an item sits can change every year. The bigger shift is further out. From 2028 more criteria could be added, such as microplastics, carbon and energy use, litter potential, resource depletion and water and nutrient impacts. There are still several unknowns in this space.
Suppliers will need to be closely involved in providing that information. Once the ratings are announced, Joosten’s advice was to collect it against every brand product so that brands can do their best to avoid red fees.
Some brands may accept a red fee instead. Cork is the obvious example. Under the current rules cork earns a red rating because the UK has no nationwide system to collect and recycle it. The challenge is consumers expect cork when it comes to wine. It shapes the user experience and how a drinker imagines the quality of a bottle of wine, however the fees could increasingly incentivise producers to move to aluminium screw caps.
Hospitality pays twice
EPR was designed to fund household waste collection. The trade argues that the regulations wrongly classify most on-premise packaging as household waste. Much of the drinks trade sells into pubs, restaurants and hotels that already pay for commercial waste collection. The exemption process for non-household packaging does not work well for drinks. It is difficult to apply for the exemption and evidence is hard to provide. It breaks down further when the product moves through a wholesaler.
The British Beer and Pub Association (BBPA) put figures on the problem in August. Pubs already pay private contractors to recycle their glass. They are then charged a second time for the same bottles because the packaging is classed as household waste, "even though they are patently not". The BBPA estimates the double charge at about £50m a year, the equivalent of 4,400 pub jobs. By its calculation pubs have already been charged around £100m. If nothing changes it warns the total could reach £250m by the end of the current parliamentary term in 2029. That estimate is just for pubs. The problem is much larger than this as it affects restaurants, bars, clubs and potentially all other hospitality venues selling glass.
The BBPA also says EPR fees leave brewers with no profit on glass bottles. Costs then travel down the supply chain until pubs and customers foot the bill. It cites the government's own estimate that consumers would end up bearing 85% of EPR costs.
The WSTA and UKHospitality have pressed the point since before the scheme went live. The government has agreed to explore an alternative approach yet, more than 2 years down the line, nothing has been confirmed.
Defra steps in on recovery notes
October brought one notable development. Producers turning over £2 million or more and handling more than 50 tonnes of packaging a year, have to prove that a certain amount of packaging has been recycled each year. To prove this producers buy packaging recovery notes (PRNs) as proof that packaging has been recycled. At the start of the year the government tightened the system and Defra replaced the old packaging database with a new reporting system. These changes meant exporters had to wait until the waste was received abroad before the PRNs were issued. This change was introduced to tackle fraud and improve transparency, but it also meant far fewer notes were then available, causing prices to skyrocket. For 2026 Defra in response to this lowered obligation amounts producers were required to recycle for three materials in shortest supply this year – plastic, steel and wood. The change is temporary and applies to 2026 only.
Glass is not on the list, despite huge price volatility in the past. For a drinks business the exposure sits in plastic closures, steel caps and wooden cases rather than the bottle.
EPR remains a live policy debate, so assumptions built into budgets should be reviewed regularly.
EPR is a data problem before it is a cost problem
The panel summed up the evening bluntly saying EPR is fundamentally a data management problem for the drinks trade.
Brands need weights and materials for every component, across primary, secondary and tertiary packaging through to shipping covering bottles, closures, capsules, labels, cases, pallets and shipping materials. Much of it sits with suppliers, often overseas. Hartley’s advice was to ask suppliers for data at the start of the relationship. It only gets harder the longer the relationship runs.
Thresholds matter too. Producers with turnover above £1 million and more than 25 tonnes of packaging fall into the scheme as small producers and are required to report once a year. Above £2 million and 50 tonnes they become large producers and are required to report twice a year. Large producers are also required to pay disposal fees. A brand that picks up a supermarket listing can cross the line very quickly.
Evidence matters as much as the figures. If a regulator asks why a pack was rated amber or green, a business needs to show where its numbers came from. Joosten’s view was that a clear paper trail is the best defence when a supplier's information is under review.
Deposit return and the Welsh question
The Deposit Return Scheme (DRS) for drinks containers is due to launch on 1 October 2027. The policy is devolved and Exchange for Change is the designated deposit management organisation for the whole UK. A flat 20p deposit has been confirmed for PET plastic bottles and steeel and aluminium cans.
Producers need to register. Initial producer registration has opened through the Exchange for Change portal. Barcodes on in-scope products will need to change and be registered before the scheme launches next year. The panel pointed out that an international barcode will not be enough for a product sold in the UK. Packaging must also carry scheme compliance indicators, such as the official logo and scheme-specific barcodes. Reverse vending machines and logistics networks use them to recognise and verify items, as well as prevent fraud.
Covering the regulations in Wales ended up being a surprise focus of the panel, taking up considerably more of the evening than anyone had planned. Wales is the only part of the UK planning to include glass in the DRS scheme. The introduction of an internal UK trade barrier makes it a test case for devolved policy making. A transition period gives glass a zero deposit and no mandatory labelling until 2031.
Critics point out that a zero deposit removes any financial reason for consumers to take glass to a reverse vending machine rather than use kerbside recycling. Retailers argue they are being asked to install expensive, bulky glass-compatible machines while collections are essentially unfunded by deposits and current kerbside collections are above the 90% target.
The WSTA and a coalition of trade bodies still want glass removed. They say wine and spirits account for about 70% of the glass in scope. They warn that many lines could become uneconomic to supply if brands need separate Welsh stock and add unique Welsh labels and barcodes.
What to watch
- End of November 2026: Year 2 liabilities. PackUK's expected notices of liability finally put a number on last year's packaging.
- 2027/28: red set to increase. The multiplier on red-rated packaging rises to 1.6.
- 2028: beyond recyclability. New criteria could start to shape fees.
- 2028/29: red doubles. The multiplier reaches 2.0.
- 2031: the Welsh glass transition ends. Labelling and deposit obligations for glass follow.
Analysis: treat EPR as an operating discipline, not an annual return
The panel’s most useful message was about discipline. For an industry already managing tight working capital, an unconfirmed liability is problematic. What a business can control is its information. Clean packaging data for every component and a paper trail behind will support competitiveness and adaptation to future policy changes.
EPR is a permanent data and compliance discipline rather than a one-off environmental levy. The businesses best placed for what comes next will be the ones that started treating it that way.
