UK Legislation and Policy Update Summary

Date Published: Wednesday 3rd June 2020

There are various legislative and policy developments in relation to plastics, packaging, circular economy, sustainability and the environment.  We have summarised some of the key items below.


1) Q1 2020 Plastic Packaging Recycling Data


The packaging interim recovery and recycling data for Q1 2020 data is now available from the National Packaging Waste Database (NPWD) on the Environment Agency website (see attached).


In Q1, a total of 297,947 tonnes of plastic packaging were received by UK reprocessors or exporters. It should be noted the Q1 data is still interim with a total of 13 reprocessors (4 large and 9 small) yet to report their data, and as such the current total is expected to increase slightly. The figures are higher than expected with a like-for-like data comparison with Q1 2019 showing 243,886 tonnes recycled, a 22% increase.


The 297,947 tonnes consisted of 111,252 tonnes (37%) received by UK reprocessors in the UK and 186,695 tonnes (63%) by exporters. This represents similar results to the 2019 average of 39% in the UK and 61% export.


It should be noted that the Q1 data includes a split of the plastic packaging formats which is based on ‘agreed with local agency office or based on sampling’ criteria. The splits are included in the attached Q1 data, and a breakdown by percentage is as follows:



These are broad categories, including a total of 26% ‘Other plastic packaging’. RECOUP will seek clarification on how these splits are calculated and will communicate more information on an ongoing basis.


Looking at packaging compliance costs, the ongoing inflated PRN values have scaled back and are trading at around £250 per tonne (this was around £300 in Q4 2019). The implications for PRNs in the current COVID-19 situation are unclear and RECOUP is completing ongoing research to understand the impact across our member base.


2) Scotland’s Deposit Return Scheme Becomes Law


The Scottish Parliament voted to approve the regulations for the Scottish Government’s Deposit Return Scheme to become law and a ‘go-live’ date of 1 July 2022 is confirmed for the scheme.


Some key points around the announcement are:

Timing - In March of this year, the implementation of the scheme was pushed back to 2022, after initially being planned for April 2021, to allow businesses more time to prepare in light of the pandemic. However, Scottish businesses would continue to be “monitored closely to see if further flexibility is required” to the implementation date.

Dates - Some dates in the run up to the implementation of the live scheme include:

  • The laws around the identification and exemptions of return points (1 January 2021); and
  • Identification and registration process of eligible packaging producers who will be affected by DRS (1 January 2022).
  • The Scottish Government making changes to the regulations which included a commitment to review the performance of the scheme by October 2026, including the deposit level, materials and the collection targets.

Materials and Fee - They are maintaining the approach to materials, with glass included alongside PET plastic and aluminium and steel. A flat deposit fee of 20p will be applied to all sizes of container.

Scheme Administrator - Now it is passed into law, details on how to apply to become a scheme administrator(s) that will run Scotland’s Deposit Return Scheme will be available shortly.

More Information - Click here to view the regulations online, and for more information on how the DRS will work, click here.


3) HMRC Plastics Packaging Tax Consultation Extended


HM Treasury announced a number of revised deadlines for tax consultations having recognised there are many sectors interested in this policy that are being affected by COVID-19.  They have taken the decision to extend the Plastics Packaging Tax consultation deadline to 20 August 2020, to give stakeholders time to submit their views.  We expect the introduction date for the tax to remain as April 2022.


In the announcement the government stated that:

  • The extension will ensure those facing COVID-19 disruption will have the opportunity to share their view on possible tax changes; and
  • Despite the extension of publication deadlines, owing to COVID-19, the government remains committed to all planned reforms.

While welcoming the opportunity for further development and evidence gathering time, we remain committed to delivering a coherent and balanced response as a priority.


4) Welsh Consultation Response


The Welsh Government previously announced a ban on the sale of single use plastics by mid-2021, that follows the EU Single-Use Plastics Directive.


RECOUP have provided a final response in relation to the Beyond Recycling Consultation, which is available should you wish to use it, and is included with this Stakeholder Update.


5) BSI Standards Ltd Develop PAS 510


BSI Standards Ltd, the UK National Standards Body, has developed and introduced PAS 510.


A PAS (Publicly Available Specification) is a sponsored, fast-track, consensus-building, standardisation document which defines good practice and is a powerful way to establish the integrity of an approach.  Produced by BSI Standards Ltd, it can be a route to BS, EN or ISO standards.


The development of PAS 510 has been sponsored by Marine Scotland, the British Plastics Federation (BPF) and members of The Investor Forum who are being represented by Fauna & Flora International (FFI).


The primary objective of the PAS 510 project is the development of a standardisation document that specifies measures to prevent the leakage of plastic pellets, powders and flakes, across the supply chain into the environment. The PAS also specifies procedures for implementation of the measures and continual improvement.  This approach is in line with efforts to transition to a circular economy for plastics.  The PAS is intended for international application as well as within the UK market.


All comments on PAS 510, during its 4-week public consultation, are to be submitted via the BSI online Standards Development Portal - - in January 2021. This involvement does not involve attendance of meetings.


Further information on the development of PAS 510, including the PAS process, schedule, PAS scope and how to get involved, is included with this Stakeholder Update.

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