SUEZ publishes review of Defra producer-responsibility proposals

SUEZ has today (Thursday 18 April 2019) published a report providing a critical review of Defra’s proposed plans and options for a new extended producer responsibility (EPR) regime.

The report, entitled Unpackaging extended producer responsibility consultation proposals, is a follow-up to SUEZ’s Unpackaging extended producer responsibility report, which was published in September 2018 and set out 10 principles for the UK to achieve a world-class producer-responsibility regime.

In its latest publication, SUEZ provides an assessment of Defra’s proposals against these ten principles, which were originally developed in consultation with various organisations from across the value chain.

This new assessment comes following the publication, by Defra, of its Resources and Waste Strategy (Our waste, our resources: A strategy for England) in December 2018 and the four consultation documents, which seek views on options for extended producer responsibility, collection consistency, deposit return schemes and a plastic packaging tax – all of which were published in February 2019.

Now that the detail of these policies is known, in its latest report, SUEZ provides a brief overview of the four extended producer responsibility governance models and the payment mechanisms proposed by Defra, setting out some of the high-level challenges, as well as a more detailed comparator assessment of these models against the principles for a best practice extended producer responsibility regime.

SUEZ, however, does not believe that any of the four models proposed by Defra is suitable in its entirety and instead favours building a 'hybrid' model comprising the optimum elements from each option to meet the desired outcomes – one example of which is presented in this report.

The report shows that none of the four models delivers against all ten of the original principles – SUEZ believes that the deposit based mechanism from governance model 4, combined with the element of registration, payment and control from the other options of governance, best delivers against the principles of a good extended producer responsibility system.

The author of the report, and Technical Development Director at SUEZ, Stuart Hayward-Higham said: “With the publication of this short report we have sought to share insight from our own analysis, our sector experience and our discussions with partners and stakeholders across the value chain. We have used this to assess the extent to which Defra’s various options meet the ambitions we set out last year, with others, for a world-class extended producer responsibility regime which brings us a step closer to the circular economy we all strive for.

"We applaud Defra for the work that they have done, but having conducted our own comprehensive analysis in collaboration with many others, do not believe any single model of those presented in the consultation documents delivers on all ten of the principles of a world-class extended producer responsibility system. As such, SUEZ favours a hybrid model, the construction of which we discuss in the report.”