Designing Packaging for Extended Producer Responsibility (EPR)

Extended Producer Responsibility (EPR) is changing the way businesses approach packaging design, by making sustainability and recyclability fundamental considerations. Under EPR regulations, obligated businesses are financially responsible for the environmental impact of their packaging, including collection, recycling, and disposal. Designing packaging with EPR in mind can help businesses reduce compliance costs, improve sustainability credentials, and meet growing consumer expectations.

• Polluter Pays Principle: Businesses obligated under EPR must fund the collection, sorting, processing, and recycling of their packaging, ensuring they take responsibility for its entire lifecycle.
• Packaging Recovery Notes (PRNs): A key mechanism in packaging regulations, PRNs require businesses to purchase certificates that finance the recycling of materials. This applies to both household and non-household packaging.
• Circular Economy: A system focused on minimising waste and maximizing resource efficiency through reuse, repair, and recycling. The Circular Economy Package (CEP) is a key policy framework that supports this transition and includes regulations like EPR to promote sustainable material management across industries.
• Modulated Fees: Charges based on packaging recyclability and environmental impact that fund local authorities for collection, sorting, and processing household packaging waste. These fees – determined by the Recyclability Assessment Methodology (RAM) – are in addition to PRN obligations, further incentivizing the use of easily recyclable materials.

1.      Modulated Fees

For household packaging, EPR introduces modulated fees, where producers pay based on the recyclability and environmental impact of each packaging component. As part of this system, the Recyclability Assessment Methodology (RAM) is a mandatory framework used to evaluate each element. The less recyclable a material, the higher the cost.

Key factors include:

• How widely the material is accepted in recycling systems
• Whether components can be separated by hand
• The presence of contaminants that reduce material quality for recycling

Designing EPR-friendly packaging helps businesses control compliance costs by prioritising easily recyclable materials and minimising non-recyclable elements.

Related content: The Recyclability Assessment Methodology (RAM): What Packaging Producers Need to Know

It’s also crucial to consider how easily packaging components can be separated by hand. For example, while glass bottles are widely recycled, elements like paper labels, aluminium collars, or plastic-backed labels can downgrade recyclability. If materials cannot be manually separated, they are often assessed together under the predominant material, which may place the item in a lower recyclability category – increasing costs.

2.      Consumer Expectations

Sustainability is a growing priority for consumers, influencing purchasing decisions and brand perception. Businesses that adopt sustainable packaging can enhance their reputation and customer loyalty.

A 2024 PwC Voice of the Consumer Survey found that:

• 85% of consumers prioritize sustainable consumption
• Shoppers are willing to pay a 7% premium for eco-friendly products

This presents a clear business opportunity – investing in sustainable packaging not only meets consumer demand but also justifies premium pricing, strengthening brand value and long-term profitability.

3.     Regulatory Compliance

EPR regulations are evolving, and businesses must stay ahead to avoid unexpected costs. Future-proofing packaging now ensures long-term compliance, reducing the risk of financial penalties and costly redesigns as regulations become stricter. Aligning early with legislative changes also enhances supply chain resilience and brand reputation.

The direction of EPR is clear – there is a growing emphasis on:

• Accurate data reporting
• Easier-to-recycle materials
• Increased use of recycled content

Businesses that proactively improve recyclability can reduce compliance costs and build consumer trust. In France, early adopters of eco-modulated EPR fees benefited from lower costs by designing fully recyclable packaging.

With the Labour Party committing to the Circular Economy Package, UK businesses should prepare for stricter recycling targets and material requirements. By anticipating these changes and adopting sustainable packaging strategies now, businesses can ensure compliance, reduce costs, and remain competitive in a rapidly evolving regulatory landscape.

1.      Prioritise Recyclable Materials

EPR encourages producers to use widely recycled materials such as clear PET (polyethylene terephthalate), HDPE (high-density polyethylene), glass, aluminum, and cardboard. However, packaging may still be classified as less recyclable if it contains non-removable labels, adhesives, or multi-material components.

For example, a glass jar with a paper label and metal lid may not be fully recyclable if the label cannot be easily removed, shifting its classification from ‘Green’ (highly recyclable) to ‘Amber’ (moderately recyclable) under the Recyclability Assessment Methodology (RAM).

2.      How Packaging Components Are Assessed

Under RAM, each element of a package is evaluated individually. So, for example, as an indicative example, consider a typical jam jar and:

• Glass jar + paper label → Amber (label is not easily removed)
• Steel lid → Green (fully recyclable)
• Hessian tie & fabric lid cover → Red (non-recyclable textile)

These assessments directly impact modulated fees, making design choices critical for cost control.

Best Practices for Recyclability:

✅ Avoid composite materials (e.g., plastic-coated paper) unless they can be easily separated.
✅ Opt for mono-materials instead of multi-layered packaging to simplify recycling.
✅ Use minimal adhesives that don’t hinder recyclability.

3.      Reduce Unnecessary Packaging

• Minimise material use while maintaining product protection.
• Eliminate excess plastic wraps, laminates, and non-recyclable coatings.
• Optimize packaging design for transport and storage to reduce carbon emissions.
• Ensure labels and adhesives are easily removable for better recyclability.

4.      Simplify Labelling for Better Sorting

• Provide clear recycling instructions to guide consumers on proper disposal.
• Use labels that do not interfere with recyclability (e.g., paper labels on glass instead of plastic-backed labels).

5.     Encourage Reuse & Refill Models

♻ Explore refillable or returnable packaging to align with consumer demand for sustainable solutions.
♻ Use durable materials that extend packaging life, such as glass bottles in deposit return schemes.

By integrating these EPR-friendly design principles, businesses can reduce compliance costs, enhance recyclability, and support a more sustainable packaging system.

1.      Lower Compliance Costs

Optimising packaging design for recyclability helps reduce EPR-related fees, lowering overall compliance costs.

2.      Enhanced Brand Reputation

Consumers increasingly prefer eco-friendly brands, making sustainable packaging a key driver of customer trust and loyalty.

3.      Future-Proofing Your Business

Proactively adapting to EPR regulations prevents costly, last-minute redesigns as legislation evolves.

At Clarity, we provide businesses with the expert guidance and tools needed to navigate EPR regulations effectively:

✔ Expert Compliance Support – Tailored advice on optimizing packaging for sustainability and cost efficiency.

✔ EPR Cost Forecasting Tools – Helping businesses manage and anticipate compliance-related expenses.

✔ Sustainability Insights – Aligning packaging design with current and future regulatory requirements.

✔ AI-Powered Product Cost Assessment – Our proprietary platform, Clarion, provides detailed cost analysis at the product level.

Designing with EPR in mind is more than just meeting regulations—it’s a chance to reduce costs, enhance brand perception, and support a circular economy.

Need expert guidance on EPR compliance? Contact our team today, and one of our experts will be in touch to help.