UKHospitality: Double trouble

Like the rest of the hospitality industry, contract caterers have plenty on their plate right now. Therefore, the prospect of having to stump up twice to dispose of packaging under new rules is an unwelcome – and potentially costly – distraction.

This prospective ‘double penalty’ is down to ill-thought-through and complex Extender Producer Responsibility (EPR) rules that are set to be introduced by the Department for Environment, Food and Rural Affairs (Defra) in October 2025. And contract caterers, with thousands of tonnes of packaging to dispose of every year through commercial contracts with waste management companies such as Veolia and Biffa, are bang in line to be caught by unfair double charging.

Under EPR, the likes of contract caterers will be held responsible for the end-of-life consequences of packaging ending up in household waste, with producers being responsible for the collection, sorting, recycling or disposal of their product packaging – the ‘polluter pays’ principle. They will need to assess the packaging activities they fulfil, including whether they import packaging into the UK, are a brand owner, distribute packaging, and how much packaging they handle and supply. Annual turnover will also be taken into consideration.

However, most packaging classed as household waste will never actually make it out of contract caterers’ premises or their clients’ venues, and will be disposed of commercially. This incorrect classification of most packaging as household waste means caterers face paying a commercial waste fee and an EPR charge. This ‘double counting’ also contradicts Defra’s intention that EPR will have a single point of compliance.

For this reason, UKHospitality has written to Defra secretary of state Steve Reed urging him to introduce a clear and simple route for demonstrating that packaging is non-household and therefore exempt from EPR charges. A good example would be beer or wine that is classified as household waste, but is clearly sold for consumption on premise, with the empty bottles being collected and disposed of commercially.

We also want EPR to enable the supply chain, including contract caterers, to calculate the proportion of packaging provided to hospitality customers to enable the correct fees are being paid, and double charging is avoided. Yes, tracking packaging is logistically complex, but a clear and simple route for contract caterers and their customers is essential if they’re to avoid paying twice simply because a process is too involved.

Businesses likely to be affected by EPR should already be submitting data on packaging they handle and supply – what the packaging is, its weight, etc – with the latest set due to have been submitted for ‘large organisations’ by 1^st October. UKHospitality continues to engage with Defra, underlining concerns around the wider cost implications of EPR, and stressing the importance of EPR not resulting in fees being passed along the supply chain to our sector.

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