Caterers and food service providers find themselves at an interesting juncture. Impending changes to handling packaging waste promise to reshape catering operations - from sourcing materials to managing waste streams.
EPR is a legal framework designed to hold producers accountable for the costs associated with collecting, managing, and recycling packaging materials. Set to begin being implemented by the UK Government this year, it encourages businesses to create more recyclable products by applying modulation fees based on a product’s recyclability.
The soonest date to have in your diary is this: by March 31, 2025, non-household premises, including businesses (except ‘micro-firms’ with fewer than 10 full-time equivalent employees), will be required to recycle all recyclable waste streams. These include plastic, metal, glass, paper/card, and food waste, but not garden waste.
The AVA supports operators and suppliers in the vending and unattended retail sectors, including schools, colleges, universities, and hospitals. The insights shared here will outline the steps that caterers should take to prepare for this new era of environmental stewardship.
Fee structure and operator responsibilities
When EPR takes effect, specific thresholds will trigger new financial responsibilities for certain companies. Businesses with an annual turnover exceeding £2m and using over 50 tonnes of eligible packaging annually will incur ‘modulated’ fees based on quantity and recyclability.
The fee calculations focus on packaging bearing the company’s branding. For instance, if a company distributes drinks in cups featuring its logo, all associated packaging counts towards its tonnage responsibility.
Conversely, if the packaging is unbranded, responsibility shifts to the cup manufacturer. This aspect of the regulation underscores the importance of collaboration between various stakeholders, such as universities with branded cups and their catering partners.
They must work closely to ensure accurate reporting of packaging use. These stipulations necessitate careful coordination and communication among all parties involved to comply effectively with the upcoming EPR requirements.
Mandatory cup takeback revoked
The UK Government has scrapped the mandatory cup takeback scheme, which was intended to be part of the extended producer responsibility for packaging regulations. Developed by the previous administration, Defra cited excessive costs and limited environmental impact as reasons for the cancellation.
However, this doesn’t prevent caterers from implementing their own voluntary recycling programmes. For example, the University of Sussex is one of many UK universities to have implemented an innovative pricing strategy to promote sustainable behaviour and reduce paper cup usage. Instead of offering discounts for reusable mugs, they’ve set the reusable mug price as the default with a surcharge for paper cups.
A lecturer at the university explains that this ‘charge rather than discount’ approach effectively nudges consumer behaviour. It addresses the gap between people’s intentions and actions by providing financial incentives and social proof.
The university also works with a paper-cup recycling scheme to ensure discarded cups are correctly recycled. However, by revoking the cup takeback scheme, a UK-wide ‘single-use cup levy’, similar to Scotland’s approach, may now be more likely.
Consequently, we advise operators to maintain collaboration with clients and current waste contractors. They should continue collecting and recycling single-use paper cups in line with ‘Simpler Recycling’ guidelines to be ready for any potential changes.
Deposit return schemes
Defra recently reaffirmed its commitment to launching a Deposit Return Scheme (DRS) in October 2027, with regulations for England and Northern Ireland now allowing for the appointment of Deposit Management Organisations this April.
The AVA and its members support a unified DRS for PET bottles and cans across the UK. Thanks to our lobbying, Defra’s current profile exempts premises with only vending machine sales of in-scope drinks containers from operating return points.
For caterers, the immediate impact is minimal. However, there may be opportunities to install return machines in large public spaces like university campuses, hospital visitor centres, or school grounds in the coming years. This could promote further recycling in these areas, while caterers may consider offering products with less plastic packaging in addition.
What operators can do
To comply with the new EPR regulations and cope with its trickle-down effects, operators should consider the following actions:
Collaborate with suppliers and contractors
Partner with vendors that use sustainable packaging or provide products designed for recycling or extended use. For instance, source reusable cafeteria serving materials or educational supplies with minimal non-recyclable content.
Develop sector-specific strategies
Schools and universities would do well by encouraging student involvement in ‘green campus’ initiatives or eco clubs to strengthen internal engagement. They should also consider fostering curriculum-based projects focused on waste reduction and management, such as student-led recycling initiatives.
Educate and involve staff, students, and visitors
Run campaigns or training sessions on EPR compliance and proper waste segregation for teachers, students, staff, healthcare professionals, and visitors.
Schools and universities should involve students and faculty in sustainability projects and new recycling methods. Similarly, hospitals should engage nursing and medical staff to ensure compliance. The responsibility for this sits with the contractor, not the operator. But partnering with an operator that is clued into the relevant changes and their impact will make a difference.
Partner with the right organisations
The AVA supports members for EPR though our network, and with regular updates and guidelines on what they need to do in preparation for these changes. Having partnerships with vendors that are in the know and ready is essential for success.
To gain access to expert support, industry insights, and a network of professionals, visit the AVA website at www.the-ava.com.