Extended Producer Responsibility beta reassessment
Service Standard assessment report Extended Producer Responsibility (EPR) 25/07/2024
Service Standard assessment report
Extended Producer Responsibility (EPR)
| Assessment date: | 25/07/2024 |
| Stage: | Beta reassessment |
| Result: | Amber |
| Service provider: | Defra |
Previous assessment reports
Service description
- Extended producer responsibility for packaging is based on the principle “the polluter pays”. This means producers of packaging become responsible for the full cost local authorities incur when collecting & disposing of packaging waste. This is expected to reduce the amount of packaging that enters the waste stream, and to improve the choice of materials used in packaging, both of which will positively impact the environment. The purpose of the service is to support the implementation of new regulations for packaging and packaging waste.
- The Environment Act (2021) grants the Secretary of State for Environment, Food and Rural Affairs powers to introduce a new statutory instrument to replace ‘The Producer Responsibility Obligations (Packaging Waste) Regulations 2007’ referred to as Producer Responsibility (PR) for Packaging with ‘The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2023’ referred to as Extended Producer Responsibility (EPR) for Packaging.
- The objective of EPR is to make obligated producers responsible for packaging they ‘place on the market’ including costs for collection, treatment and recycling of household and on the go (street bins) packaging waste. This responsibility is expected to extend the outcomes of PR towards more sustainable packaging design.
- ‘Producers’ in these regulations are commercial organisations who in the course of business benefit from packaging used in the UK. EPR works on a principle of ‘single point of compliance’ whereby the Producer with the most influence is responsible for all costs.
- Producers obligated under EPR are required to apply for producer and annual registrations with the appropriate environmental regulator by providing business, packaging, and recycling information, paying an application fee, declaring any household packaging waste, paying a household packaging waste disposal fee (where applicable), paying a scheme administration fee (where applicable) and paying a contingency fee (where applicable).
- Producers can be members of a ‘Compliance Scheme’ that undertakes some obligation activities on behalf of members.
- Environmental regulators are required to approve Producer registrations and notify the Scheme Administrator where a Producer declares household packaging waste liability.
- The Scheme Administrator is required to calculate the disposal and scheme administration costs payable by each Producer (where applicable), notify Producers of these, publish a list of commonly binned items, and manage payments and account balances.
- To meet these requirements the service supports user authentication, service enrolment, account authorisation, user and account management, producer and annual registration application approvals, recycling obligation statements, household waste disposal cost calculation, fee(s) payments, and financial management.
- Registration approvals are issued by the regulator following a review and validation of application information and the relevant payments. To support this process the service supports compliance monitoring, enforcement, and customer relationship management.
- In addition, the service will support scheme management including KPI reporting.
Service users
Current service users are grouped into four categories:
- large producers of packaging (organisation)
- third-party consultants (individuals)
- compliance scheme operators (organisation)
- environmental regulators (organisation)
Things the service team has done well:
- the team was engaged, and keen to share knowledge to deliver their key outcomes effectively.
- the team outlined well the policy context, delivery pressure and constraints under which they have been operating. It was clear from the presentation that the decisions they had made were justified and evidence based, and the trade-offs well thought through. The team was functioning well as a team across a complex policy and delivery space.
- the content challenges were well outlined by the content designer.
- during the reassessment, plans for accessibility testing were presented that showed the issue had been acknowledged. These plans will need to be followed through to ensure that the service is both compliant with accessibility requirements, and that it works as an end-to-end service for users of assisted technology.
- the plan for recruiting users with accessibility needs was well structured. It is also worth considering how these users can support the development of the content strategy, especially for ‘lexically dense’ concepts and the service’s reliance on content to support task completion. The team has a performance analyst on-board with a plan on how the service will measure success and continue to iterate based on analytics and user feedback.
4. Make the service simple to use
Decision
The service was rated amber for point 4 of the Standard.
During the assessment, we didn’t see evidence of:
- the previous assessment suggested evidence was required for designing inclusive and accessible services and alternative service routes. During the reassessment, plans for accessibility were presented that showed the issue had been acknowledged. These plans will need to be followed through to ensure that the service is both compliant with accessibility requirements, and that it works as an end-to-end service for users of assisted technology.
- similarly, the service team detailed an outline of the telephony support journey and how the ‘backend’ is being supported that gave confidence to assessors.
- it would also be interesting in the future to understand the team’s strategy for supporting technical change within the wider industry (for example use of APIs) and how to reduce data duplication via development of the technical architecture and data model.
6. Have a multidisciplinary team
Decision
The service was rated green for 6 of the Standard.
10. Define what success looks like and publish performance data
Decision
The service was rated amber for point 10 of the Standard.
During the assessment, we didn’t see evidence of:
- How and when the exit survey will be implemented on to the service.
Next Steps
This service can now move into a public beta phase, subject to addressing the recommendations given for the amber points in within three months’ time and CDDO spend approval.
This service now has permission to launch on a GOV.UK service domain with a Beta banner. These instructions explain how to set up your *.service.gov.uk domain.
The service must pass a live assessment before:
- turning off the legacy service
- reducing the team’s resource to a ‘business as usual’ team, or
- removing the ‘beta’ banner from the service