Why the new French approach to packaging compliance may hold the answer to developing the UK system

9th February 2018

It is fair to say that the UK PRN (Packaging Recovery Note) based Producer Responsibility (Packaging Waste) Regulations have not been universally popular since its introduction in 1997. With the current targets running out in 2020, and a growing drive to change the system following increased concerns about the state of UK recycling compared with waste exported overseas, there may well be pressure to amend the regulations over the coming years

One common complaint of producers is that the current system does not really reward (and thus encourage) recyclability in product design. It is possible for companies which recycle their products directly to get accreditation to produce their own PRNs but this does little to reward companies whom purchase non-virgin, polymer-based packaging. As consumer awareness around plastic waste and brand investment in recycling is becoming increasingly mainstream, it would appear to be the perfect time to offer some form of relief within the system for companies using recycled content in their products / packaging.

This was touched on in the Packflow 2025 report released in 2017, within the context of a strategic system which introduces a materials fund. The purpose of the fund would be to allow investment into the recycling industry and in return, producers would be offered recyclability bonuses (in the form of reduced fees or money returned). Whilst the concept of the fund itself would provide (arguably much needed) investment into the UK recycling sector, the “rewards for recyclability” appear to be at most, a complementary measure.

Changes to the French System

France currently operates a “Costs Covered” system whereby the company placing packaging on the market pays for the full collection, recycling, treatment and recovery costs of waste packaging. This system aims to provide a high recycling rate and maximise producer engagement with the recycling of waste packaging. The system is considerably more expensive for some producers than that in the UK.

One major change that is coming into the French Regulations in 2018, is the addition of enforced Bonuses and Penalties based on the material type of the packaging itself.


The bonuses (reductions in the levy payable by producers) are split between Raising Awareness, Reduction and Recyclability. There are various bonuses within these categories but they can be summarised as below:

Raising Awareness

This offers up to an 8% reduction from the levy paid on packaging when correct recycling labelling is applied, with the aim of increasing consumer understanding of what can, and can’t be recycled. An interesting development here is the inclusion of a bonus for using a QR code-based information label. In the UK, OPRL (On Pack Recycling Label) is considered the most informative recyclability label, and this bonus could well be brought in line with OPRL usage as stated in the Packflow 2025 report. There are industry murmurs on the possible inclusion of a QR code within the OPRL which would allow people to work out exactly what they can and can’t put in their bin in the UK.


In this instance, the aim is around reducing the quantity of packaging weight on a product. So, if in the product’s first year of sale on the French market, a suitable reduction in the packaging weight is demonstrated (for example by concentrating a liquid product), an 8% bonus is applied. This bonus also requires a recyclability increase, for example consolidating materials. If these changes are documented and published in an approved “Citeo” catalogue, a further 4% bonus is applied.


There are separate bonuses of 12% and 8% respectively for the use of widely recycled plastics and for rigid plastics eligible to be readily sorted and recycled.


There are a range of penalties which can be applied. If any penalty is applied to packaging, that same packaging is then exempt from bonuses.

100% penalties are added to PET containing Mineral Opacifiers and also to packaging not currently recycled readily.

Possibly the most interesting penalty to review from a UK perspective is the 50% penalty added to “disruptive packaging”. This includes products such as multi material composites (plastic / paper composites) which are not easily separated and as such are considerably disruptive to the recycling stream, examples include disposable coffee cups. Recently we have seen an increase in public concern around disruptive packaging such as plastic lined paper coffee cups in the UK. The introduction of a UK penalty system similar to that in France could account for the additional cost associated with sorting and recycling disruptive packaging.

Why these changes could help the UK?

As discussed earlier, there are many concerns regarding the current lack of reward for recyclability (or punishment for the usage of non-recycled / recyclable material), and reviewing a system such as the French one would allow for the UK to offer more producer engagement and a competitive reason to review recyclability in product design.

Amendments such as those to the French system may be possible to implement into the UK Producer Responsibility Regulations, but would require considerable stakeholder engagement and regulation change. At the very least, when considering future amendments, the French approach to rewarding recyclability could be used as a guideline for the production of a system that retains the competitive pricing benefits of the UK PRN system, whilst encouraging competitive change from packaging producers that supports a more “Circular” method of product design. As there is currently a growing populist interest in solving “Problem Packaging” such as disposable coffee cups, a rewards-based system may offer benefits to consumers, retailers and manufacturers whilst promoting a demand for recycled materials and encouraging investment into UK recycling.

Recently, the European commission put forward VAT amendment proposals which would allow member states to have more flexibility on VAT rates offered on certain products. This could potentially allow member states to apply VAT reductions on products which have a higher recycled content or are more readily recyclable than industry averages.

Stay tuned for more information on changes Packaging Compliance and if you would like to let us know your thoughts on the regulations moving forwards, please feel free to fill in our survey.