Here is a draft of a letter that we sent to our respective members of parliament, showing our concern about the new Extended Producer Responsibility (EPR) measures. To us, they seem arbitrary, badly thought-out, and counter-productive in the extreme, damaging the profitably of small businesses and, in the end, increasing costs for the consumer. In the final analysis, it is even highly doubtful that they will have the desired positive environmental effect.
This is another example of successive governments not consulting with the hospitality industry on a number of measures that create bureaucratic upheaval, add costs, and impact on everyone. Small businesses are the backbone of a thriving economy, but rather than supporting and stimulating their growth, governments seem determined to erect ever more financial barriers.
Dear,
I am writing to highlight serious concerns regarding the new Waste Packaging Extended Producer Responsibility (EPR) scheme, that urgently need to be addressed ahead of its scheduled implementation on April 1st.
I work for Les Caves de Pyrene, a UK-based wine import-distribution company that has been operating in the drinks and hospitality sector for over 35 years. While we are supportive of legislation that holds businesses to account for the waste packaging they produce, it is imperative that such legislation is carefully considered, appropriately directed, and financially viable for the businesses it targets. Regrettably, the EPR scheme set for implementation next month fails to meet any of these criteria.
In its current form, the legislation will obligate us to pay EPR charges associated with all primary packaging that isn’t otherwise categorised as ‘non-household’. At first glance, that makes some sense – the fees paid by us would help to offset the significant costs associated with improvements to government & council-funded household waste streams. However, under its current definition, the non-household category fails to recognise the hospitality sector as a ‘business final user’ without the provision of impossibly impractical supporting evidence. As such we have been notified that all primary packaging sold to this sector will be considered ‘household’ and as such we will be liable for the full weight of recycling costs associated with every bottle sold; the same bottles that our hospitality customers already pay to recycle through their own commercial waste management arrangements.
Despite the scheme’s scheduled introduction, accurate EPR rates remain yet to be confirmed, leaving businesses unable to accurately budget for the significant costs we face. The current illustrative fee for glass within this scheme is an astonishing £240 per tonne, eight times higher than the rate currently charged in Belgium and the highest rate anywhere in Europe. For reference, this fee represents a forecast cost to our business of over £400,000 per year. It is also important to note that these exorbitant new fees are due to be introduced alongside the existing waste packaging obligations which already see businesses responsible for the purchase of Packaging Recovery Notes (PRNs). Glass PRNs were most recently forecast at a price of £110/tonne, resulting in an estimated overall cost of £350/tonne. Businesses will simply not be able to afford such levies and, directly or indirectly, the impact of this legislation will ultimately be felt by the already crumbling hospitality sector.
The UK wine trade, and hospitality in particular, has taken a financial battering in recent years, and most acutely during the last 12 months. Brexit, which saw many European workers leave the country, combined with COVID which saw longstanding restaurant staff turn to more financially secure professions, and magnified by new legislation regarding service charge distributions have collectively seen staff costs sky-rocket; increased duty rates on alcohol and a general increase in the cost of goods continue to put growing pressure on pricing and margins; and a significant downturn in consumer activity in this sector as a result of the ongoing economic crisis have all resulted in unprecedented levels of hospitality closures, affecting everything from small independent sites to Michelin starred titans. Implementing the new EPR scheme in its current format will only add to these pressures and risk financial devastation for an industry that provides almost 3 million jobs and delivers over £60bn GVA to the UK economy each year.
Implementing such high charges also risks actively discouraging producers from using glass, a 100% recyclable material, in favour of lighter but more environmentally damaging materials such as plastic. If such punitive measures are to be implemented at the cost of millions of jobs and livelihoods, please let them at least serve the purpose for which they were intended.
Simply put, the scheme cannot go ahead in its current format and needs urgent attention before fees begin to accrue in April. I would kindly ask that you raise this as a matter of urgency with your colleagues, and by any means possible in Parliament.
Yours sincerely,
Les Caves de Pyrene
