Compliance at a glance
August 2025

The Circular Economy Taskforce plan to publish their Circular Economy (CE) strategy in late autumn. The CE strategy will be published as a Green Paper for public consultation and EEE has been identified as one of the priority workstreams.

The areas likely to be consulted on regarding EEE & WEEE include topics such as:

• the need for a major piece of research on options for increasing reuse
• extending EPR to the charity/reuse sector
• aligning with EU legislation and international standards to promote eco design;
• further enhancements to the WEEE communications campaign;
• changes to the way equipment is collected
• retailers no longer able to send surplus equipment to landfill

The measures put forward for consultation will reflect the current political/economic climate, where the priority is not to burden business with additional costs;  nor increase costs for householders.

Ecogenesys will continue to monitor the progress of the CE Strategy and Green Paper and will continue to update Members as appropriate.

The UK ETS Scheme, which came into effect in January 2021, provides a mechanism for charging for greenhouse gas emissions from sectors within the scope of the scheme. Whilst emissions from waste incinerators were originally excluded from the scheme, the UK Government has since consulted on the inclusion of these, which will commence from 1st January 2028.

The Government has recently published their response to a further consultation, in which they considered implementation of a prior Monitoring, Reporting and Verification (“MRV”) stage, through which operators can measure and report their independently verified greenhouse gas emissions, with the submitted data being used to help develop and test the carbon allowance and pricing factors that will apply from 2028 onwards.

It is in their response to this consultation that they confirmed the impact of inclusion of waste incinerators on packaging producer EPR Fees. They confirmed “the UK ETS will align with pEPR so that the additional carbon costs incurred by local authorities for disposing of packaging materials through incineration are considered as part of the calculation of the pEPR payments for the efficient management of household packaging”.  Where packaging enters the residual waste stream, if it is incinerated, producers will be responsible for the ETS costs of this packaging.

With packaging currently estimated as accounting for 60% (this is prior to mandatory collection of flexible plastics being implemented by Local Authorities in England) of the greenhouse gas emissions from residual waste and annual waste incineration costs under ETS in the region of £700 million, producers Disposal Fees could increase significantly.

On the 17^th and 18^th September, Ecogenesys will be at the Environmental Services and Solutions (ESS) Expo at Birmingham NEC, sponsoring the Central Networking Bar at RWM (the Resource and Waste Management Expo). The ESS Expo is the UK’s leading environmental services and sustainability event incorporating:

• Waste and recycling
• Water management
• Energy and resource
• Land management
• Air and emissions

With over 12,000 attendees, the expo is an important networking opportunity. Speakers at the event include the Environment Agency, PackUK, WRAP, ESA and Material Focus.

If you are interested in attending and would like to arrange an in-person meeting with the Ecogenesys team, contact your account manager.

Registration is free and tickets are available here: >>https://forms.reg.buzz/ess-2025