Securing fair and sustainable policies and reforms for pubs and brewers.
We support our members to navigate reforms to packaging and waste policy, to ensure fairness, transparency and a sustainable future for our industry.
Below are the main policy areas we are currently working on with alongside our pubs and breweries.
A deposit return scheme (DRS) for single-use drinks containers is set to be introduced across the UK in October 2025.
The aim of any DRS is to help improve the quality and quantity of recycling, reduce litter and help to achieve climate change targets.
A DRS works by charging a small deposit on certain drink containers at the point of purchase. Consumers can then get their deposit back once the drinks container has been returned to a designated collection point.
What next?
As a sector we recognise the important role Deposit Return Schemes can play in reducing environmental impacts and contributing towards a circular economy. We are committed to working collaboratively and cohesively across-sectors, as well as with the Scottish Government, DEFRA, DAERA and the Welsh Government to ensure a DRS which is functional and effective across the UK is implemented. However, it is important to note, the proposed schemes will add very significant cost and complexity into brewing and pub operations and supply chains at a time when the sector already faces significant cost challenges.
Scotland
The DRS in Scotland was set to go live on 16th August 2023. However, following only a partial exemption to the UK Internal Market Act, which changed the scope (to remove glass) and added additional requirements which were unclear, the Scottish Government after discussion with industry decided to delay introduction and align with the rest of the UK to go live in October 2025. In order to comply with the partial IMA exemption, Scotland will be removing glass from their scheme and only charge deposits on PET and aluminium.
Since moving to alignment with the rest of the UK, the Scottish scheme is undergoing several serious revaluations. The Scottish Beer and Pub Association (SBPA) regularly engages with the Scottish Government to understand the new positioning on DRS in Scotland.
More information on DRS in Scotland:
Zero Waste Scotland – Deposit Return Scheme FAQ
SEPA – Deposit Return Scheme regulations and obligations
Scottish Deposit Return Scheme: UK `internal market exclusion
England/Wales/Northern Ireland
DRS for the rest of the UK is not as far along as in Scotland due to the original divergence in go-live dates.
England, Wales and Northern Ireland are currently working to finalise the regulations to launch the scheme, with a framework outlining how to apply to be the Deposit Management Organisation (DMO). Until a DMO is appointed, the BBPA is engaging on the form and function of the scheme and preparing members for likely impacts.
Once a DMO is appointed, likely in summer 2024, they will work with producers, retail, hospitality, and third sector groups to ensure that all parties understand the obligations and opportunities presented by the scheme.
Unlike England, Northern Ireland, and now Scotland, Wales intends to maintain glass as a product in scope of DRS.
Further information about the England, Wales, and Northern Ireland DRS can be found here:
Further Extended Producer Responsibility (EPR) measures are currently being phased in to increase responsibility producers have for the packaging they place on the market.
The aim is to incentivise producers to use less materials and ensure what they do us is more easily recyclable packaging materials.
The Government published their final EPR reforms proposals that will commence in 2024 (with some data reporting requirements in 2023) in March 2022.
Key points from DEFRA’s response included:
- Producers to pay the full net costs of household waste via a modulated fee system to encourage greater use of recyclable packaging.
- Further work on payments for non-household waste will continue. As an interim measure the current PRN/PERN system will also continue to ensure recycling targets are met – at least until 2027.
- The governments say the overall annual costs of EPR will reduce by £1bn from £2.7bn in the consultations to £1.7bn in the final proposals.
- The EPR Scheme Administrator (SA) will be classified within the public sector. Government still wish to see significant industry involvement.
- EPR implementation delayed a year from 2023 to 2024. This will involve partial EPR implementation from 1st April 2024 relating to local authorities’ costs; and full implementation of EPR in 2025 based on modulated fees.
- The EPR response confirmed that in England and Northern Ireland, glass will be excluded from DRS (and so be covered under wider EPR proposals). Wales, however, will follow Scotland in including glass bottles as well as cans and PET bottles.
The BBPA continue to work closely with members in relation to their ongoing concerns with the EPR proposals, to assist with compliance and to encourage Governments in all devolved nations to create a system that is simultaneously sustainable and effective throughout the entirety of the UK.
As part of existing Extended Producer Responsibility obligations, Organisations who meet below specific thresholds are obligated by packaging regulations to finance the recovery and recycling of packaging materials in proportion to the amount they have placed on the market.
- Company turnover exceeds £2M annually.
- Company handles 50 tonnes of packaging annually.
In order to demonstrate they have taken action, obligated businesses are required to purchase Packaging Recovery Notes (PRNs) to prove that an equivalent amount of packaging has been recycled, recovered or exported.
You can see our explanation of the PRN system, and its failings, here.
PRN Consultation Response October 2022
DEFRA’s response to the consultation on reforms to the Packaging Waste Recycling Note (PRN) and Packaging Waste Export Recycling Note (PERN) system was published in October.
The consultation closed in May and was initially opened alongside the government’s EPR response which outlined DEFRA’s plans to continue with the PRN/PERN system until at least 2026 to 2027.
The consultation was intended to address some of the issues identified in the current system, including PRN and PERN price volatility, a lack of transparency, and the potential for fraudulent issuing of PRNs and PERNs.
The consultation response positively outlined plans to introduce monthly reporting of reprocessing and export data, as well as monthly price and revenue data reporting, by reprocessors and exporters. It did not however do anything to address spiraling costs producers continue to face in 2023.
The BBPA continue to inform Government that urgent action remains necessary to alleviate the immense pressures the current volatile PRN market is placing on producers.
The BBPA operates its own packaging compliance scheme to help members discharge their obligations under the packaging EPR regulations. The scheme is managed by compliance experts Ecosurety who support members in submitting their packaging data to the environmental regulators, determining their respective tonnages and purchasing the required PRNs. For more information on this please contact Finlay Morriss.
The BBPA has created guidance for those wishing to reduce the use of plastic in licensed premises through cutting down on plastic straws. After a number of environmental campaigns, and wide support from the general public, the BBPA and members have committed to reducing the use of plastics in their pubs.
This guidance highlights some of the alternatives to plastic straws.