FWD column: Responsibility and reality balancing

FWD Chair Dawood Pervez updates on Extended Producer Responsibility (EPR) and FWD’s lobbying to help shape policy

If there’s one policy that has dominated the wholesale sector’s agenda in recent months it’s Extended Producer Responsibility (EPR). And rightly so.

EPR poses a significant shift in the way packaging waste is funded and managed, and while the principle of ‘polluter pays’ is understandable, its current structure raises serious challenges for wholesalers and our suppliers.

Let’s start with the latest update. The government has now confirmed the final base fees for 2025 and there is some welcome news: fees for nearly all materials have been reduced, with glass down 20% compared to earlier estimates. This is a result of timely data submissions by industry – proof that when we engage constructively, we can influence outcomes. But that doesn’t mean the sector is out of the woods.

The introduction of modulated fees from 2026 onwards will present fresh complexity.

Packaging will be ranked red, amber or green based on recyclability, with red-rated materials carrying a higher cost burden. This shift is intended to nudge businesses toward more sustainable packaging choices and while many suppliers are already innovating, wholesalers will be left to manage the pricing, communication and, critically, the potential confusion for end customers.

FUNDAMENTAL CONCERNS

FWD has consistently argued that reforms must work with the supply chain, not against it. In May, FWD wrote to the prime minister, alongside a coalition of trade associations, to highlight three fundamental concerns: the effect on investment due to prolonged uncertainty; the risk of double payment for hospitality businesses (many of whom source via wholesale); and disproportionate cost burdens, especially on glass, which has a high recycling rate but was initially set to incur the steepest fees.

We’re pleased that these concerns are being heard. The government has now confirmed that councils must spend EPR funding only on household packaging waste services, with penalties for non-compliance. This is a welcome accountability measure, but we will continue to press for transparency in how those funds are used.

More importantly for wholesalers, work is underway to address dual-use packaging – the kind of packaging that might end up in either a business or a household bin. Much of this packaging is supplied via wholesale and, until recently, risked being classified as household packaging simply by default.

After months of engagement, including direct conversations with Defra and active participation in ministerial workshops, FWD is helping shape sector-specific proposals that better reflect the commercial reality of our operations. It’s also important to remember that wholesalers will be directly responsible for EPR obligations on any packaging they place on the market under their own-brand labels or on products they import into the UK themselves.

This is not abstract policy. These decisions will impact costs, customer pricing, packaging choices and, ultimately, business viability. Some members would have faced millions in additional costs if earlier definitions had remained. Thanks to persistent lobbying, those costs have been significantly reduced.

REGULAR UPDATES

EPR also featured prominently at our FWD Live! annual conference in June. In the Policy Hub, it was the most-talked-about issue, with members expressing concern not just about the costs but about the lack of clarity on implementation. That’s why we are continuing to provide regular updates, ensuring businesses are not left in the dark.

We’ve said before that sustainable sourcing and packaging are no longer optional; they’re becoming expected. And in many ways, EPR presents an opportunity to accelerate positive change. But the pace and complexity of reform must not punish the very businesses that are trying to do the right thing.

FWD will continue to be a strong voice for wholesalers, engaging with government, holding officials to account and ensuring our members are supported every step of the way. We’ll also keep championing realistic, phased transitions that allow for innovation and adaptation, not sudden and costly disruption.

Dawood Pervez Defra extended producer responsibility FWD column FWDLive! Government