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8 October 2021 General


As part of WRAP’s Defra advisory group on litter payments under EPR, the FPA provided a response to a paper titled 'Key Requirements for Quantifying the Cost of Littered Packaging by Producers’ on the methods used to quantify littered packaging and the producer costs in dealing with it. The document will be used to inform the still-to-be-appointed EPR Scheme Administrator. We raised a number of issues and are pleased to note that WRAP has taken many on board in the updated document.

We requested the introduction, which claimed littering was mostly due to foodservice packaging, be withdrawn as the claim is not supported by Keep Britain Tidy’s most recent litter compositional survey. The statement has been withdrawn, and the words 'ground litter exists because of citizen behaviour’ have been added.

We are also pleased that, following our plea to ensure business is not expected to pay twice for waste management of packaging, the following now appears: 'Producers should only pay once for disposal costs, and therefore a method will be required to ensure that they are not charged for treatment of packaging via kerbside collections or DRS’.

In response to our request for a level playing field regarding litter payments, WRAP has included the following sentence: 'It is recommended that the extension of litter payments to other key items such as cigarette butts is made in parallel to EPR for packaging'.
This all adds up to a more balanced document in keeping with the required principle of ensuring fairness with regard to charging businesses.

We would now like to see a fresh approach to litter data collection, one which enables seasonality, weather, time of day to be taken into account as well as tracking and identifying more items as proposed by WRAP. The current method options and associated costs prohibit more regular surveys and, as business is to be charged for litter, then data needs to be robust and less open to challenge. The use of drones has recently been employed in a non Defra litter survey. Newer technology must be assessed as a way of achieving greater accuracy.