The association is urging Exchange For Change to ensure its decisions avoid unintended consequences that distort markets and undermine sustainability objectives, such as considering how decisions on flat-rate deposits impact scheme delivery and be wary of the interplay between different policy areas.
“Policy design must avoid incentivising consumer behaviour that runs counter to wider goals on circularity, food waste and portion control. The objective of packaging reforms should be to reward circularity performance, not to create winners and losers through skewed policy intervention,” it said.
While the MPMA acknowledged that Defra faces a complex challenge, it said a wholesale discounting of glass pEPR fees is ‘not the answer if it increases the burden on steel food cans’.
The association pointed out that beverage cans are the most recycled drinks container in the world (International Aluminium Institute study, 2022), highly valued within recycling systems because aluminium has a high resale value – a key element of recycling any material.
Jason Galley, director and chief executive of MPMA, said the appointment removes a major barrier to progress and interoperability between the UK’s schemes: “But attention must now shift quickly to delivery and avoiding unintended consequences.
“After a period of delay and uncertainty, the metal packaging sector needs clarity, momentum and a practical route to interoperability if UK-wide schemes are to be on schedule and deliver the environmental benefits they promise. With a little over a year until the launch date in October 2027, there is no room for further delay. Success will depend on rapid, coordinated action to establish infrastructure, prepare businesses and build consumer buy-in.”
He added that Exchange for Change and policymakers must be mindful of the unintended consequences that can arise from seemingly simple policy decisions.
“One area requiring careful reconsideration is the proposed use of a flat-rate deposit across all beverage containers, regardless of size, material and recyclability. The financial burden on consumers should not be underestimated. A shopper buying 10 x 250ml canned beverages would face an additional £1.80 upfront deposit versus a single 2.5l plastic bottle through the flat-rate deposit of 20p per container. At a time when household budgets remain under pressure, these additional fees risk undermining public support for the scheme.”