SUEZ publish critical review of Defra’s plans for a new EPR scheme

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Waste management firm SUEZ has published a new report which provides a critical review of Defra’s proposed plans and options for a new extended producer responsibility (EPR) scheme.  

The report, called Unpackaging extended producer responsibility consultation proposals, is a follow-up to its September 2018 report that set out 10 principles for the UK to achieve a ‘world-class’ producer-responsibility regime.  


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In this recent report, SUEZ provides an evaluation of Defra’s proposals against these 10 principles, which were originally developed in consultation with various organisations from across the value chain.  

This new assessment follows the Resources and Waste Strategy in December 2018, and the four consultation documents, which seek views on options for EPR, collection consistency, deposit return schemes and plastic packaging tax, all of which were published in February 2019. 

SUEZ’s latest report provides a brief overview of the four EPR 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 EPR scheme. 

The firm has said that it does not believe that any of the four models proposed by Defra is suitable in its entirety and instead favours building a ‘hybrid’ model encompassing the optimum elements from each option to meet the desired results.  

Suez believes that the deposit-based mechanism from governance model 4, combined with the element of registration, payment and control from other options of governance, best delivers against the principles of a good EPR system.  

Author of the report and SUEZ technical development director 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.” 

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