Crushed By Compliance? What EPR Means For Hospitality

By Melissa Haskell, regulatory partner at Knights (www.knightsplc.com)

The introduction of the United Kingdom’s Extended Producer Responsibility (EPR) regime in April marked a significant shift in how packaging waste is managed across sectors. Its central aim – to place the cost of managing packaging waste on those who produce it – aligns with the hospitality sector’s long-standing commitment to sustainability and environmental stewardship.

However, while the principles of EPR are widely welcomed by operators, challenges with its implementation have surfaced that risk placing undue financial strain on pubs and hospitality businesses. For instance, industry estimates suggest the sector could face an additional £60 million in annual costs. That’s the equivalent of 5,000 jobs, largely driven by duplicate charges for glass waste that is already collected and recycled through commercial contracts.

Glass attracts weight-based EPR fees of £240 per tonne, nearly ten times the equivalent rate in Germany. For many operators, particularly independent pubs, this creates a double burden: first through existing commercial waste collection agreements, and then again through EPR fees. This raises concerns over fairness and clarity, particularly as some of the glass waste in question never enters the household waste stream in the first place.

These are not complaints about the idea of EPR itself – far from it.

Most operators recognise and support the environmental rationale. But for the scheme to succeed, its design must better reflect the day-to-day realities of hospitality. Clearer categorisation, greater transparency, and smarter implementation would go a long way in helping businesses uphold compliance without threatening commercial viability.

Packaging a better outcome
Glass packaging is more than just a container. From cask ales to fine wines and craft spirits, it forms part of the identity and experience hospitality businesses offer. It is also a material with one of the highest recyclability rates. Yet under current rules, it is disproportionately penalised in the fee structure. This has prompted some suppliers to consider shifting to alternatives such as aluminium or plastic, which – while lighter – may undermine the very sustainability outcomes EPR is designed to promote.

Industry trade organisations including UKHospitality and the British Beer & Pub Association have raised these concerns with policymakers and are asking for a 12 month pause to allow for refinements to the system. Their goal is not to delay progress, but to ensure the scheme is fit for purpose. The current lack of clarity on modulated fees, retrospective charges, and definitions around household versus commercial waste leaves many operators – particularly smaller venues – facing uncertainty and potential liabilities.

Practical steps for resilience and compliance
In the face of these complexities, businesses should take a proactive stance. EPR is now live, and compliance is not optional. But there are constructive actions that can mitigate risks and support the sector’s collective voice.

Engaging directly with Defra and contributing to ongoing consultations is essential. Industry letters and local BID involvement are also important channels to raise operational realities and seek clarification. Businesses should avoid relying on second-hand guidance and instead pursue information from official sources to ensure accuracy.

Operators should also review contracts with both suppliers and waste providers. Understanding exactly how packaging enters and exits the premises, and how waste is categorised, can identify opportunities to recategorise material or share costs with upstream producers.

Exploring alternative packaging formats, such as boxed wine or lighter-weight bottles, can also help reduce EPR exposure. While not every substitution will be feasible, particularly where brand perception and product preservation are key, being open to innovation supports both cost control and sustainability aims.

Training staff in the latest waste classification, and maintaining accurate records of packaging data, will become increasingly important. Local authorities and environmental health teams may step in if practices fall short, potentially affecting future expansion or refurbishment plans. Robust compliance not only avoids fines, but also builds confidence among investors, suppliers, and customers.

Finally, local collaboration could offer shared benefits. Hospitality businesses may consider pooling waste disposal resources, joining rebate schemes, or working with bottle collection charities to reduce administrative overhead and recover value from materials.

From regulation to opportunity
The consequences of non-compliance are not minor. Civil penalties can range into the millions, and while few operators are likely to face the most extreme outcomes, smaller fines can still significantly impact already tight margins. Just as importantly, falling short on environmental regulation can damage hard-won reputations.

But by taking the right steps now – seeking clarity, building resilience, and contributing to ongoing reform – hospitality businesses can help shape a system that works better for everyone.

EPR has the potential to drive meaningful environmental progress. With collaboration between policymakers and operators, it can also support the long-term viability of the UK’s vibrant hospitality sector. Rather than seeing EPR as a burden, the industry has a chance to help refine it into a model of shared responsibility and practical sustainability. By engaging early and constructively, hospitality can lead the way toward a fairer, greener future.