- MPMA asserts that the variations in densities among different packaging materials have not been appropriately accounted for in the establishment of the illustrative packaging Extended Producer Responsibility (pEPR) fees. This oversight could steer both commercial and consumer choices toward less recyclable materials, jeopardizing the metal packaging sector which supports over 5,000 jobs and contributes approximately £4 billion to the UK economy annually.
- The trade body expresses concern that the unintended repercussions of the Government’s scheme could lead to heightened metal packaging costs, potential job losses within the sector, unforeseen shifts in consumer and commercial behavior, and ultimately, the disappearance of the classic metal food can — a staple found in kitchens across the country.
- Metal food cans boast a long shelf life, playing a vital role in ensuring food security within the UK.
- The recycling rate for metal packaging is among the highest in the UK, with a remarkable 76 percent (source: DEFRA).
- Unless adjustments are made, MPMA contends that the Government’s scheme will directly contradict its sustainability objectives aimed at enhancing the circular economy.
MPMA urges the Government to critically evaluate its illustrative packaging pEPR fee structure, cautioning that, if left unchecked, it could jeopardize the future of the iconic metal food can — one of the most sustainable packaging options that, thanks to its longevity, is crucial for food security in the UK.
The trade body warns that these pEPR fees may incite “serious and nonsensical market distortion,” which could have “calamitous” effects on food security, given that the densities of various packaging materials have not been adequately taken into account by the Government when determining these illustrative fees.
Representing 22 member companies in the metal packaging industry, MPMA has formally communicated with the Secretary of State for Business and Trade and the Secretary of State for Environment, Food and Rural Affairs, outlining the potential unintended effects of the recently announced illustrative pEPR fees. The organization believes that unless the fee structure undergoes a review, the Government’s initiative will contradict its intentions to reduce packaging waste, enhance recycling rates, and foster a more efficient circular economy.
Jason Galley, MPMA Director and Chief Executive, states:
“Our examination of the illustrative packaging Extended Producer Responsibility fees reveals that the base fees for metal cans are significantly higher than those applied to less circular materials.”
“The disparity in fees among materials is substantial enough to influence purchasing decisions by brands and retailers toward less circular options. Consequently, this promotes the replacement of steel cans with larger quantities of less circular materials that will require processing, all while generating diminished fee revenue. This situation would be counterproductive and stands in stark contradiction to the objectives of EPR, presenting a perverse market distortion that endangers our sector.”
“Ultimately, this trend could result in the decline of the metal food can, an essential item found in kitchen cupboards, as manufacturers pivot away from producing metal packaging — which, despite its infinite recyclability, may become financially unviable.”
“It is MPMA’s position that it would be disastrous for a Government sustainability initiative to place the UK’s food can industry at risk. This sector plays a crucial role in food security and efforts to reduce food waste. Given that metal packaging boasts the highest recycling rates in the UK, the DEFRA policy seems entirely counterproductive to its stated aims.”
Galley continues:
“If implemented, the proposed pEPR fees would induce significant and irrational market distortion, leading to increased costs associated with managing packaging waste and potentially resulting in job losses in the metal packaging sector, alongside decreasing pEPR revenue for the Government.”
“MPMA’s members are dedicated to integrating sustainability within societal and business practices. However, we are concerned that the EPR scheme’s fee policy will not achieve the environmental performance envisioned by the Government, while simultaneously posing a direct risk to the UK’s food security.”
MPMA’s Perspective Elaborated
- Metals (and glass) are recognized as Permanent Materials, meaning they can be recycled repeatedly without losing quality, rendering them ideal for a circular economy. Food cans, with a shelf life of three to five years, are essential for preserving food security and minimizing food waste.
- The illustrative pEPR fees fail to consider the varying densities of different packaging materials. As a result, denser materials like metals and glass face disproportionately high fees, potentially pricing them out of the market, while less dense and less recyclable materials such as plastics and fiber composites gain traction. For instance, the fee per cubic meter of steel could be five times greater than that for fiber composites.
- Such pEPR fees might ironically increase packaging usage due to material substitution, leading to the replacement of a smaller volume of metal packaging with a larger quantity of less recyclable and less circular options. Notably, just six cubic centimeters of steel are used for a food can, while roughly three times that volume of plastic or fiber composites is required for the equivalent pack size.
- This fee-driven shift toward a greater quantity of less circular materials will elevate the costs associated with handling packaging waste and simultaneously diminish the revenue collected to address this waste management. This is counterproductive concerning circularity, fee generation, and job creation. It poses significant risks of market distortion in the metal packaging sector, job losses, and escalating costs in handling packaging waste, all while reducing pEPR revenue.
- In a study focusing solely on soup containers, MPMA found that base fees for a metal can exceed £5.00 per thousand units compared to those for a less recycled fiber composite container. This staggering difference will significantly influence purchasing decisions made by brands and retailers, steering them toward less sustainable products.
- A similar fee distortion is expected to emerge between steel cans and plastic soup containers as Defra applies fee modulation.
- History offers insights into the drawbacks of vilifying higher-density materials. During the 2000s under the “Courtauld agreement,” the result was the transition from billions of recyclable food cans — particularly for pet food — to lighter, non-recyclable pouches. These pouches have since contributed to landfills and incineration, while the metal that could have been used for food cans remains in circulation today. MPMA regards Defra’s illustrative fees as likely fostering similar detrimental changes. It is critical to protect the UK’s food can industry, which is vital for food security and reducing food waste.