More than 80 businesses, led by the Wine and Spirit Trade Association (WSTA), have penned a joint letter to Ministers explaining their concerns over the scheme.
In it, the consortium asked government to ‘put the brakes’ on until fees are known, business has time to prepare and the Department for Environment, Food and Rural Affairs’ (Defra’s) own guidance is completed.
While the organisation agreed with EPR in principle, the fees for the scheme will not be known until summer 2025, six months after the it begins. As such, producers argue it’s impossible to estimate the cost to businesses and ultimately consumers.
‘Not ready to roll out’
Miles Beale, chief executive of the WSTA, said: “Defra sensibly delayed EPR by one year, however it is clear that the scheme is not ready to roll out and a further delay is required to make sure the costs are realistic and known in advance.
“Wine and spirit businesses are working towards using less packaging and making it more recyclable, but the scheme currently set out is unfair and unfit for purpose. A delay would mean industry and Defra could work together to find a fairer, clearer and more sustainable resolution.”
The WSTA argued there is insufficient clarity for a commercial organisation to set pricing strategies, including the extent to which they will pass new costs onto customers or adjust pricing or contracts with retailers.
Condor Wines co-founder and managing director Lee Evans added: “As an SME, or any type of business, when setting pricing you cannot afford to wrongly forecast your costs and with EPR we are still not able to see accurate figures. Our customers need us to provide 2025 pricing before mid-December, so we are already working internally to forecast and prepare for these changes.
Lack of clarity
“Without a lack of clarity on EPR costs we are more likely to wrongly forecast and this could be detrimental to our business. I support the WSTA in their efforts to delay and seek more details before implementation of EPR, thus allowing us sufficient time to properly forecast and prepare.”
The WSTA warned there were other aspects of EPR still not ready including: setting up the scheme administrator to operate EPR modulated fees due in year two; calculations for fees; mandatory labelling; amendments to the current legislation; or accounting guidance. It was also unclear if glass was included in EPR or DRS in Wales.
Julian Momen, Enotria&Coe CEO, said the scheme’s illustrative fees disproportionately affected glass, threatening the wine and spirits sector and potentially diverting investment by overseas producers away from the UK.
“We urge DEFRA to adopt a simpler, unit-based approach, fostering a competitive market for all packaging materials, and to delay EPR implementation to align with the introduction of the Deposit Return Scheme,” said Momen.
Concha y Toro general manager Simon Doyle agreed that while the policy objectives may be clear, the process of implementation is not.
Collecting taxes
“Producers are to be responsible for collecting another tax on behalf of government without certainty on what these taxes will be, how we should collect them or account for them,” said Doyle.
“It is critical that Defra and all involved in managing EPR listen to the legitimate concerns of the wine industry and take stock of how much more effective implementation could be if due time were given to work collaboratively to find a sustainable and manageable way forward.
“Alongside duty reform, this new government couldn’t have a clearer opportunity to put into practice its claims of listening and wanting to remove bureaucratic barriers to business.”
Meanwhile, the appointment of a Producer Responsibility Organisation to support with the rollout of new EPR legislation has been confirmed by ministers.