Untangling Extended Producer Responsibility

Mandatory Takeback Obligation

National Cup Recycling Scheme Members welcome the proposal to make takeback of paper cups mandatory as this would place all businesses selling drinks in paper cups on a level playing field. It would also increase the number of cup recycling points available making it easier for consumers to recycle their paper cups. Within the wider context of EPR, it will be important that the investment in infrastructure for paper cup recycling can be traced separately than funding used to grow the UK’s general recycling infrastructure. In addition, the reformed EPR system should be designed so that it avoids charging producers through both EPR fees and the mandatory takeback obligation.

A Phased Approach

Government is proposing that the mandatory takeback obligation would be introduced via a phased approach with large sellers required to meet the obligation by the end of 2023, extending to all sellers by the end of 2025, with a potential exemption for small and micro businesses. It would be sensible for the exemption to be based on the size of the store, for example, where a store does not have space to install cup recycling bins and store paper cups.

The misconception that paper cups cannot be recycled remains the biggest barrier to increasing paper cup recycling rates. Applying the mandatory takeback obligation to all sellers from the outset would alleviate consumer confusion surrounding paper cup recycling.

Modulated Fees

As part of wider EPR reform Government plans to introduce a modulated fee system like those that exist in France and Sweden under which the amount businesses are obligated to pay will increase or decrease depending on the recyclability of the packaging. Paper cups may look very similar, however, not all types of paper cup can be recycled in the same way. And so, it is important for the system is designed in a way that reflects the recyclability of the paper cup. This would mean allocating a lower fee to paper cups that can be recycled and have a dedicated separate waste stream. Over time this would reduce the amount of contamination and increase the volume of high value material captured by a separate paper cup recycling stream.  

Recycling Targets

In addition to the mandatory takeback obligation Government is also intending to announce a recycling target for fibre based composite packaging from 2026 which would include disposable fibre-based cups. From a standing start in 2018, the National Cup Recycling Scheme has achieved a recycling rate of 6% based on the number of cups Scheme Members placed onto the market in 2019. Therefore, it is essential that any targets set are reasonable and achievable if they are to support an increase the number of paper cups being recycled.

Collaboration Is Key

As a result of the voluntary collaboration of producers, waste collectors and reprocessors, the National Cup Recycling Scheme has made significant progress toward increasing the number of paper cups recycled. The introduction of a mandatory takeback obligation would build on the Scheme’s success and facilitate an increase in paper cup recycling in the UK.   

For more information on the National Cup Recycling Scheme please email: