Take-back Schemes, pEPR and RAM
Key takeaways: What is a take-back scheme and what does this mean for producers
Starting in 2025, producers are required to assess the recyclability of packaging likely to be disposed of by households, or in public bins, against the RAM (Recyclability Assessment Methodology) laid out by the pEPR Scheme Administrator, PackUK.
As part of the recyclability assessment, producers must determine how widely collected their packaging is from households across the UK.
The level of collection from households determines the output (Red, Amber, Green) of the material at the start of its recyclability assessment or what it will be capped at. For example, packaging that has only a Limited Collection (collected from between 50-75% households) will start at Amber and wouldn’t be able to have a Green output.
| Percentage of households packaging is collected from | Level of collection |
| Collected from more than 75% households | Widely Collected (capped at Green) |
| Collected from between 50-75% households | Limited Collection (capped at Amber) |
| Less than 50% collection from households | No Collection (capped at Red) |
For an explanation of how UK collection percentages are calculated, please refer to the guidance. By consulting the guidance, producers can determine where their packaging fits on the collection scale.
Examples:
- Glass is collected by 89% of UK local authorities, with certain stipulations, meaning it would fall under 'Widely Collected'
- Fibre-Based Composites (FBCs), e.g., liquid cartons are collected by 66% of local authorities, meaning they would fall under 'Limited Collection' and be capped at an Amber rating.
For packaging that falls into the 'No Collection' category, all is not lost. Take-back schemes offer a way for materials and packaging types to be collected and processed outside of kerbside collections, with packaging captured by these schemes being able to improve from Red to be capped at Amber.
The guidance specifies five key criteria for an accepted take-back scheme:
- The accessibility of the scheme – Collection points must be accessible between 9am-5pm within a 5-mile radius (considering multiple forms of transport) for 75% or more of the population. This includes adequate signposting and accessibility to those with disabilities.
- No conflict with kerbside collections – Collection points must have no active competition with materials already collected at kerbside, or encouragement to use the collection system in the place of kerbside collections.
- No brand restrictions – Schemes must accept packaging from other brands that have a similar format.
- No purchase requirements – Proof of purchase is not required to use the take-back scheme.
- Full traceability of materials reprocessed – A defined end-market for the reprocessed material collected from the scheme must be evidencable, with transparency in the tons of material reprocessed, including contaminating materials.
For producers to be able to report their packaging in line with this guidance, they will need to contact their chosen take-back scheme to provide confirmation and evidence that the scheme meets all five of the above criteria.
Gaps and challenges
Looking at the guidance, it is easy to see the challenges that take-back schemes, and therefore producers, face.
Firstly, we have the accessibility of the scheme. How is a scheme operator expected to gather this information and where are they to find the data? Should an operator look at populations of the local authorities, or population hotspots, where collection points are located to determine if 75% population coverage is met?
What about online return take-back schemes? Being online technically means they cover nearly 100% of the country, but do they meet the accessibility criteria when it comes to ‘adequate signage’ or population knowledge?
There are also the issues around traceability and evidence of recycling. The general fact that these packaging materials and formats aren’t collected from households leads to issues around recycling infrastructure, end-markets, and the processing of contamination.
If we look at flexible polyolefin plastics which are currently collected from larger supermarkets, do we actually have the traceability in the system to say that this material is recycled at scale with a defined end market?
Opportunities
There are opportunities for scheme operators in these challenges though.
There are the general considerations for scheme operators, such as the fact that each supermarket runs a separate take-back scheme; therefore, the population coverage would need to be assessed for each scheme individually, and not as a whole, unless all the schemes were to join together as a single scheme.
There is also the consideration of ‘self-managed consumer waste’ (SMCW) in the pEPR regulations where producers can ‘offset’ their financial obligations by collecting and recycling packaging from consumers that is not commonly collected from kerbsides. Relevant packaging would be reported in a producer’s submission under the activity ‘self-managed consumer waste’ and is unrelated to recyclability assessments.
Considering the polyolefin plastic take-back schemes; the evidence required by the producer-operator to offset the tonnages from their pEPR submissions through the ‘self-managed consumer waste’ approach could meet some of the traceability criteria outlined in the take-back scheme guidance.
It’s important to note that SMCW isn’t subject to the same criteria as take-back schemes and could therefore be easier for producers to evidence if they meet the following criteria:
- packaging can be reported as SMCW if it isn’t collected by 75% of authorities in the UK, or is reusable packaging that has been used at least once,
- has been collected from consumers and sent for recycling at the producer’s own cost, and
- the producer has evidence that the material has been recycled.
Finally, we have reuse, which PackUK have stated as one of their focuses for the near future. Reuse and reusable packaging has the potential to remove recurring pEPR fees as packaging is only obligated on its first use. Reusable packaging, of any material, that is collected back from consumers and sent for recycling at the producer’s own costs, can also be counted as SMCW and deducted from pEPR fees. For example, reusable glass milk bottles collected from consumers can be reused or recycled by the producer at their end of life.
There are a variety of systems of reuse that have been highlighted with the potential to increase the ‘stickiness’ of customers to brands with refill subscriptions or branded refillable packaging.
- Consumers return the packaging to store or drop-off point, or collected from home, to be refilled by the producer
- Packaging that is refilled by the consumer at a designated refill point, e.g., in store
- Packaging that is designed to be refilled by the consumer from ‘refills’ purchased in store or through a subscription service
If you do supply materials that aren’t collected from kerbsides, it is worth considering the other alternatives aside from take-back schemes, such as SMCW or designing reusable packaging systems, when assessing your costs under pEPR.
Innovation
Interpreting RAM and the English ‘Simpler Recycling’ legislation, Beyondly believe take-back schemes could be viable to boost recycling rates for flexible plastics before Simpler Recycling comes into force, along with other packaging formats and contaminated packaging.
- Flexible polyolefin plastics (PE, and PP) are currently not collected from kerbsides, but under Simpler Recycling in England these will be widely collected for RAM in 2028.
- Cosmetics and personal care packaging is often made of small components in difficult-to-recycle packaging formats (such as ABS). There is also the possibility of contamination from product residue, such as nail varnish, or concealer. This would even potentially cover small but recyclable packaging formats, such as HDPE toothpaste tubes.
- Paint pots, glue, gardening chemicals, etc., while potentially being in recyclable packaging materials, are again often contaminated with potentially toxic materials and so are not collected from kerbsides.
There is potential in take-back schemes being setup to cover some of these formats for commercial reasons. This will hopefully lead to innovations in the collection, sortation, recycling, and reprocessing of these packaging formats which may one day lead to being included in kerbside collections, which is the preferred method of collection for recyclable materials, or dedicated return systems for material that needs specialist processing.
We look forward to seeing innovation from producers in the development of more recyclable packaging materials. Speaking to Alex Hilton, our new Director of Policy & Public Affairs and straight from leading the development of the RAM at PackUK, he adds that take-back schemes could be an enabler of innovation around new and novel materials, such as natural polymers, by forging a route to recycling, a consistent feedstock, and ultimately infrastructure development. Innovation and the development of infrastructure led by commercial interests will be the driving force behind change in these ‘problematic’ materials and formats.
Final thoughts
- Consider the cost benefits in the setting up take-back schemes versus the use of ‘self-managed consumer waste’ in the pEPR regulations
- Take-back schemes offer a potential route to recycling for materials and formats not collected from kerbside
- There are lots of considerations for scheme operators when assessing their scheme against the guidance, such as population coverage and traceability
- Considering reuse alongside take-back and self-managed consumer waste gives options when assessing pEPR disposal costs
