Trade rallies for EPR overhaul – but what can be done?
The fees for the UK’s extended producer responsibility (EPR) scheme are in, and the spirits industry is paying more than just the price.

*This feature was originally published in the July 2025 issue of The Spirits Business magazine.
A packaging reform scheme from the UK government’s Department for Environment, Food and Rural Affairs (Defra) came into effect on 1 April 2025.
A government spokesperson called the extended producer responsibility (EPR) scheme “the first step for our packaging reforms, ensuring more materials are recycled and reused”, and said over the next decade it would “create 25,000 jobs and help stimulate more than £10 billion investment in recycling”.
The scheme puts the onus on producers with an annual turnover of more than £2 million, and that sell more than 50 tonnes of packaging that falls within the scope of the scheme, to cover the entire lifecycle of costs for any packaging they introduce into the market, including collection, recycling and disposal of their packaged waste.
The principles behind the scheme might be good – cracking down on waste, holding producers accountable for reducing their waste, and, ultimately, creating a circular economy – but put into practice, they reveal a different reality for the drinks trade.
Some in the industry are disappointed at how the scheme has been implemented and the lack of consideration or leeway given to spirits makers in the UK, given they are already stretched thin, and facing numerous challenges such as tax rises. They say there has already been much progress from producers to operate sustainably, meaning the scheme feels like an unfair penalty.
The fees for the first year of the scheme were only announced on 27 June 2025, with the price for glass set at rate of £192 per tonne, compared with aluminium at a rate of £266, paper and card at £196, plastic at £423, and fibre-based composite at £461.
There is a fear these fees could distort the market. For instance, Freddie Joosten, associate director of environmental policy at trade body the Wine and Spirit Trade Association, believes producers that can swap packaging materials may use plastic or aluminium instead of glass. Glass has a higher cost per unit, so a 700ml glass bottle weighing 900g would cost more than 17p, while a 100ml plastic bottle would cost 0.5p. (If EPR costs are applied there is no fee on plastic bottles until the deposit return scheme starts, he notes).
Based on those figures, pricing on weight doesn’t feel right, and Joosten makes a case that the glass fee should be calculated on volume instead. “The glass fee is far too high and is encouraging less recyclable alternatives,” he says, “which is costly for businesses, while undermining the policy aims of EPR.”
Ruth Piggin, director of industry sustainability at the Scotch Whisky Association, also feels “poorly designed schemes” just add to the burdens that UK hospitality businesses face. She says despite ongoing engagement “the producer fees for glass announced [in June] were a deeply disappointing continuation of the UK government’s failure to engage with the concerns of businesses regarding EPR design.
“Coupled to the inflationary cost of the scheme, EPR will impose significantly higher costs on glass compared to a range of other materials, and could result in other industries switching to less sustainable materials.”
Supporting both points, Miranda Hayman, co-founder of London-based Hayman’s Gin, says the system feels “unjust and confusing”, considering glass is one of the more sustainable circular packaging methods.
Julia Massies, managing director of Pernod Ricard UK, adds that taxing glass versus non-recyclable plastic “feels counterproductive”. She says: “With confirmed costs for glass at £192 per tonne, glass will end up paying 30% of the cost on 5% of the volume. This risks incentivising the use of plastic, which is less recyclable.”
She calls for a price of £100 a tonne for glass, and would “welcome a Defra review to end double counting under EPR of bottles delivered to the hospitality sector via wholesalers”. Spirits producers are already charged for their commercial waste disposal but under the scheme, their waste would fall under the household bracket too, passed on from suppliers, meaning that producers have to pay a fee twice.
This double whammy, or ‘double counting’, is another cause for concern. Hayman wants clarity on why the hospitality industry pays twice to dispose of its packaging because “the venue pays for a waste contractor while everything they dispose of will be charged an EPR cost”.
While it’s too late to overhaul the scheme, changes have been recommended to make it more fair to the spirits industry.
Hayman says: “The current scheme does seem to be creating an unnecessarily bureaucratic and opaque system – perhaps it would make sense to create one system for sustainability/circularity tax and to simplify the application process.”
At UKHospitality, the trade body’s chair, Kate Nicholls, agrees fair changes need to be made. She calls the current version of EPR “badly designed”, and that “it is the last thing hospitality needs”. She also says its rollout has been far from ideal, explaining that “many operators have already been passed price increases by their suppliers, based on ‘base fees’ published by Defra”. Final fees for various materials were only published in June, she reiterates, just three months before the first payment is due in October.

Nicholls and UKHospitality have proposed two “clear, possible solutions” that can improve the EPR scheme, ones that “crucially, ensure that hospitality businesses are not unfairly punished through being charged twice – once in the form of an EPR fee passed on from suppliers, and again in the cost of their commercial waste disposal.”
The proposal would be “where a premise sells a packaged product for consumption both on and off- premises, there needs to be a mechanism that allows for EPR to be paid on only the volume taken in off-premises”.
Joosten wants the government to give businesses more time to prepare. “The costs have only just been finalised, yet the fees are based on calendar year 2024 data,” he says.
“Similarly modulated fees for next year should be known in advance, so producers can introduce more recyclable materials and packaging formats in advance. Applying fees retrospectively on packaging already sold is illogical and unfair.”
The penalty from EPR could be most harsh on small businesses, which will still be considered as ‘large producers’, and have to meet EPR obligations. Joosten warns: “These businesses have small teams, and will struggle to pass on costs, particularly to hospitality businesses that were told EPR would not apply to them.”
He adds: “The exemption process for hospitality waste should have been consulted on, in detail, before legislation was written. Make the changes the industry is asking for – and fast.”
Increased sustainability
It’s not as though the spirits sector hasn’t been forward in transitioning into a more sustainable industry, as Massies says of Pernod Ricard’s packaging initiatives: “As technology has improved, we have made significant progress in this area.”
She cites the recent 25% glass weight reduction for the flagship Chivas 18 bottle, which is estimated to save 500 tonnes of glass annually.
Considering the already tough trading environment, and the scheme’s “unfair” push towards lighter, less environmentally friendly materials such as plastic, Hayman says EPR “could see irreversible changes to the glass manufacturing and hospitality sectors”.
She says the government “needs to hear [that] the system is too complex and that the bureaucracy being created to manage and make business compliance is increasing business costs. This needs to be addressed as a priority”.
UKHospitality has written to prime minister Keir Starmer and chancellor Rachel Reeves, resulting in “constructive dialogue” with Defra, Nicholls says. The trade body’s proposal on double counting has been recognised, but it could take until year two of the scheme to be rectified.
“It is essential it’s in place for year two,” Nicholls warns. “We’re working with Defra on this solution and continue to impress upon the government the urgency of implementing solutions as soon as possible.”
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