Eighteen UK trade bodies have urged the government to take a more coordinated approach to packaging taxes and regulations, warning that overlapping requirements are increasing costs for businesses and consumers.

In an open letter dated 15 October and addressed to Financial Secretary to the Treasury James Murray, Defra Minister of State Emma Hardy and Business Secretary Jonathan Reynolds, the organizations called for a review of how the UK’s packaging policy measures interact and whether their cumulative costs and administrative burdens are proportionate to their environmental benefits.

The letter was coordinated by the British Brands Group and signed by organizations representing sectors including absorbent hygiene products, nonwovens, cleaning products, cosmetics, food and drink, packaging and horticulture. EDANA, the international association representing the nonwovens industry, is among the signatories.

The trade bodies said they support reducing unnecessary packaging, increasing recycling, encouraging the use of recycled materials and ensuring producers contribute appropriately to the costs of managing packaging waste. Their concern, they stressed, is how the different measures operate together.

Cumulative costs and administrative burdens

The letter identifies Packaging Extended Producer Responsibility (pEPR), the Plastic Packaging Tax (PPT) and Packaging Recovery Notes (PRNs) as separate regimes that create duplicative, divergent and inconsistent reporting and financial obligations.

Businesses must manage different timelines, payment bodies, data requirements and assessments, generating administrative costs in addition to their direct financial obligations, the signatories said.

The letter also highlights the implications of the European Union’s Packaging and Packaging Waste Regulation (PPWR), which it says will affect businesses placing products on the market in Northern Ireland or exporting to the EU.

According to the signatories, some businesses have reported substantial increases in packaging-related costs since the introduction of the reforms. One multinational company cited in the letter said its total UK packaging costs were approximately twice the norm in comparable European markets, without a corresponding improvement in packaging recovery.

Smaller brands have also reported that higher regulatory costs leave them unable to afford in-house expertise to assess alternative packaging solutions, potentially slowing the transition to more sustainable formats.

The letter provides the example of a UK fragrance importer and distributor that developed a dedicated system to convert overseas brand-owner packaging data into biannual pEPR submissions. It also describes an Environment Agency audit requiring detailed evidence, including the weight of void fill in individual cartons.

The company’s wood PRN costs had risen from approximately £7.50 per tonne in the previous year to more than £100 per tonne, according to the letter. Despite the higher price, the certificates remained largely unavailable, leaving the business unable to meet its obligation.

Concerns over consumer prices

The signatories also warned that the cumulative costs could affect product prices, particularly in sectors where packaging represents a significant share of compliance costs.

The letter argues that the government’s estimates of pEPR’s overall impact on inflation may understate the effects on individual products and sectors. It cites government estimates of a 0.07% impact on the Consumer Prices Index (CPI) and a 0.37% impact on the Retail Prices Index (RPI), while arguing that the burden may be greater in food and drink categories.

The organizations said businesses may absorb some additional costs through efficiency improvements and innovation, but that passing costs through supply chains can ultimately affect both business and household consumers.

They called for the affordability implications of packaging policy to be considered alongside environmental objectives, particularly amid pressure on household budgets.

Call for a coordinated approach

The trade bodies have asked ministers to discuss how the different packaging measures interact in practice, where unintended consequences have emerged and whether the combined financial and administrative burdens are proportionate to the environmental benefits.

They also called for greater certainty for businesses making long-term investment and packaging decisions, and for clearer, more consistent incentives supporting innovation, recyclability and packaging waste reduction.

The letter additionally highlights the forthcoming introduction of the Deposit Return Scheme for drinks manufacturers as another development to consider in coordinating packaging policy.

The signatories offered to meet with ministers to share their members’ experience of packaging redesign, investment in sustainable materials and supply-chain implementation, with the aim of improving environmental outcomes while maintaining business competitiveness and consumer affordability.

Read the full letter sent to government