Agenda item


The Committee considered the following report:


“1.0      Purpose of Report/Summary of Main Issues


1.1       To report to Committee on the draft Belfast City Council response to the Consultation onthe draftProducer Responsibility Obligations(Packaging andPackaging Waste)Regulations [2024].


2.0       Recommendation


2.1       To agree the final Belfast City Council response to the Consultationon thedraft ProducerResponsibility  Obligations  (  Packagingand PackagingWaste) Regulations[2024] as attached in Appendix 1


            Note that the consultation closed on 9th October 2023, and that officers have submitted a draft response to DEFRA, noting that a final decision by members is required and DEFRA will be advised of the final decision.



3.0       Main Report


3.1       Members may recall from the Committee meeting on 12th September 2023, that the Department for Environment, Food and Rural Affairs (DEFRA) recently launched a public consultation on draft regulations for Producer ResponsibilityObligations.


            The link to the consultation is as follows:


3.2       This consultation seeks views on how well the proposed 2024 Regulations reflect the Government Response to the proposals on the introduction of Extended Producer Responsibility (EPR) for packaging across the UK (generated by 2019 consultation on reforming the UK Packaging Producer Responsibility System and the 2021 Extended Producer Responsibility for Packaging).


3.3       The Government Response was published in March 2022 can be found here:   


3.4       Since the publication of the Government Response, the UK Government and the Devolved Administrations have been working closely to develop the draft Regulations which implement these reforms. The main objective has been to ensure that these reforms deliver sustained change.


3.5       Having reflected on industry feedback, the UK Government and the Devolved Administrations decided to defer EPR for packaging payments from October 2024 to October 2025. It is envisaged that a 12-month deferral to packaging payments will give: 


·        Industry additional time to prepare for the new requirements, which may include reviewing and improving current packaging use.

·        Industry and local authorities more opportunity to be involved in the design of the scheme.? 

·        Local authorities and waste management companies more time to adjust current services and to introduce new efficient and effective services for EPR. 


3.6       This consultation on the 2024 regulations will apply UK wide. They will revoke and replace the 2023 Regulations as well as Producer Responsibility Obligations Regulations 2007.


3.7       The draft Regulations include provisions to:


-       Enable the appointment of a Scheme Administrator.

-       Allow a Scheme Administrator to raise fees from obligated producers to cover local authority costs for the management of household and binned packaging waste, the costs of public information campaigns, and its operational costs.

-       Set recycling targets on producers covering all types of packaging waste (i.e., primary, shipment, secondary, tertiary; household and non-household). • Require certain types of packaging to be labelled to indicate recyclability.

-       Introduce a mandatory takeback and recycling requirement for fibre-based composite cups.

-       Require all reprocessors and exporters of packaging waste to register with a regulator and to report data, and, for those that choose to, to become accredited and issue recycling evidence.

-       Enable regulators to effectively monitor compliance and enforce the draft Regulations.


3.8       Belfast City Council’s draft response is attached as Appendix 1.  The consultation is technical in its nature and officers have taken on board views from other expert bodies, in particular the Local Authority Recycling Advisory Committee (UK) (LARAC) and arc21. Officers are largely in agreement with arc21’s response to the Consultation document. Where we have additional commentary or queries, this is incorporated into each individual response. Some questions (e.g. 19 and 21) are mainly focused on Producers and in these instances, industry is in a better position to respond.


3.9       As a local authority collector of household waste, the main issues expressed in our responses are:


-       clarity on the definition of ‘efficient and effective services’ and how local authorities will be assessed on this in relation to allocation of funding.  

-       How circumstances such as geography will be considered (in the above assessments) and what criteria will be applied. Belfast is a city with a demographic with few comparators in its geographic location.

-       The timing of the process and in particular, its interface with other Producer Responsibility Obligations such as the Deposit Return Scheme.

-       The continued focus on weight-based targets and application of the Waste Hierarchy, rather than considering a new modelling approach, incorporating carbon measurements.

-       The changing nature of packaging waste and how this could be affected by industry’s response to the Obligations, as well as the future impact this might have on local authorities.


3.10      Following the Consultation period, DEFRA will review the responses received andmake changes to the draft Regulations as appropriate. The draftRegulations will be made publicly available whenthey arenotified tothe WorldTradeOrganisation(WTO) andthe European Union(EU) in respectof Northern Ireland tocomply with internationalobligations. During the notification period, Government intends to publish a high-levelsummary of the responses.


3.11      Financial and Resource Implications


            None – in relation to responding to the consultation.


3.12      Equality or Good Relations Implications/

            Rural Needs Assessment


            None – in relation to responding to the consultation.”


            The Committee agreed the final Belfast City Council response to the Consultationon thedraft ProducerResponsibility  Obligations  (Packagingand PackagingWaste) Regulations[2024] available here and noted that a draft response had been submitted to DEFRA by the 9th October 2023 deadline, subject to Council ratification on 1st November.


Supporting documents: