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3 September2021 General


As part of WRAP’s Defra advisory group on litter payments under EPR, the FPA is meant to be providing a response to a paper on the methods used to quantify littered packaging and the producer costs in dealing with it, and provide the still-to-be-appointed EPR System Administrator with a recommendation. In order to form a response we have requested the raw data for Keep Britain Tidy’s 2020 litter composition survey.

We are certainly not doubting KBT and their team collecting information but the data puts packs into categories and we need to understand the data surrounding the packaging aggregated in each. In addition the KBT report refers to ‘general litter (other)’ and ‘unsure (litter cannot be determined)’. What is this litter and are we expected to pay for it? KBT has declined our request which is very disappointing. KBT is undoubtedly the expert when it comes to measuring litter, but without access to the raw data how can we be expected to comment?