- MPMA believes the densities of the different packaging materials have not been adequately considered in setting the illustrative packaging EPR fees which will drive commercial and consumer behaviour towards using less recyclable materials, adversely impacting the metal packaging sector which employs over 5000 people and contributes some £4bn to the UK economy each year.
- The trade body fears the unintended consequences of the Government scheme will lead to increased metal packaging costs, job losses in the metal packaging sector, unintended changes in consumer and commercial behaviour, and ultimately the loss of the iconic metal food can – a kitchen cupboard staple.
- Metal food cans have a long shelf-life, playing an essential role in UK food security.
- Metal packaging has among the highest recycling rate of any packaging material in the UK at 76 per cent (source DEFRA).
- Without revisions, MPMA believes the Government scheme will work in direct opposition to its sustainability goals to improve the circular economy.
MPMA is calling on the Government to interrogate its illustrative packaging Extended Producer Responsibility (pEPR) fee structure warning that, if unchecked, it could lead to the loss of the iconic metal food can – one of the most sustainable packaging materials which, due to its long shelf life, plays an essential role in UK food security.
The trade body warns that pEPR fees will bring about “serious and nonsensical market distortion” proving “calamitous” for UK food security as the densities of the different packaging materials have not been adequately considered by the Government in setting the illustrative fees.
Representing 22 member metal packaging companies, MPMA has written to the Secretary of State for Business and Trade and the Secretary of State for Environment, Food and Rural Affairs highlighting the unintended consequences of the recently published illustrative pEPR fees. MPMA fears that if the fee structure is not revised then the Government scheme will work in direct opposition to its goals to reduce packaging and waste, increase recycling rates and improve the circular economy.
Jason Galley, MPMA Director and Chief Executive says:
“Our study of the illustrative packaging Extended Producer Responsibility fees shows that the base fees for metal cans are significantly higher than for containers made from less circular materials.
“The difference in fees attracted by the different materials is high enough to drive brand and retailer purchasing behaviour towards less circular products. This will lead to steel cans being replaced by higher volumes of less circular materials which will need to be processed, while fee revenue is reduced. It would be a complete nonsense in direct opposition to the intention of EPR and is a perverse market distortion that threatens our sector.
“Ultimately, this could lead to the loss of the metal food can, an iconic presence in kitchen cupboards, as manufacturers turn away from producing metal packaging which, despite its ability to be recycled over and over, could be priced out of the market.
“It is MPMA’s view that it would be calamitous for a Government sustainability scheme to endanger the UK’s food can business which provides food security and the ability to combat food waste. When you consider that metal packaging is the most recycled packaging material in the UK, the DEFRA policy is completely counter-productive to its own aims.”
Galley continues:
“If applied, the illustrative pEPR fees will bring about serious and nonsensical market distortion that will cause increased costs in dealing with packaging waste with the potential to cause job losses in the metal packaging sector, coupled with a diminishing pEPR revenue for the Government.
“MPMA’s members are committed to embedding sustainability into societal and commercial practices. We are concerned however, that the EPR scheme’s fee policy will not drive the environmental performance the Government desires while posing a direct threat to the nation’s food security.”
MPMA’s view in detail
- Metals (and glass) are defined as Permanent Materials, which is they can be recycled over and over, without loss of quality, making them the perfect materials for a circular economy. Food cans, with their three-to-five-year shelf-life, are essential for food security and reducing food waste.
- Illustrative pEPR fees have failed to take into account the different densities of the different packaging materials. This means that denser materials like metals and glass will pay disproportionately high fees and be priced out of the market, while less dense, less circular materials like plastic and fibre composites will be proliferated. For example, the fee per m3 of steel will be five times higher than for fibre composite.
- Such pEPR fees will actually increase the amount of packaging used via material substitution. And this additional amount of packaging will be less recyclable and less circular than the smaller volume of metal packaging it replaces. Just six cubic centimetres of steel is used for a food can whereas around three times that amount of plastic or fibre composite is needed (for the equivalent pack size).
- This fee-induced drive towards higher amounts of less circular materials will push up costs for handling packaging waste and reduce the fees collected to do so. It would be counter-productive from the standpoints of circularity, fee collections and job creation. They will also bring about serious and nonsensical market distortion that will cause job losses in the metal packaging sector and increased costs in dealing with packaging waste, coupled with diminishing pEPR revenue.
- In a MPMA study on just one example of soup containers, it calculated that the base fees for a metal can are more than £5.00 per thousand units higher than for a less recycled fibre composite container. This is a huge number that will drive purchasing behaviour at brands and retailers towards less circular products.
- A similar distortion between steel cans and plastic soup containers is expected when Defra applies fee modulation.
- There is an example, from recent UK history, of the consequences of demonising higher density materials. Under the “Courtauld agreement” in the 2000s, the perverse outcome was to transition billions of cans of food, pet food in particular, from fully circular metal cans to lighter, yet unrecyclable pouches. These pouches have been ending up in landfills and incinerators ever since, while the metal that could have been used for food cans would have still largely been in circulation today. It is MPMA’s view that Defra’s illustrative fees would drive the same kind of change. It would be calamitous to endanger the UK’s food can business which provides food security and the ability to combat food waste.