EPR changed the arithmetic, quietly

For most of the time your current packaging was being designed, the cost of it being hard to recycle fell on somebody else. Extended producer responsibility moves that cost onto the producer, and modulated fees mean the amount depends on how recyclable the pack actually is.

This is a larger change to packaging economics than any material innovation of the last decade, and it arrived as an invoice rather than as news.

What it does to a business case

A substitution that was marginal on material cost alone can become obviously correct once fees are included, and a substitution that looked cheap can become expensive. We have rerun three business cases from 2023 and two of them inverted.

The direction is not always toward the "greener" option either. A pack that scores well on fees but adds transport weight can still be worse overall, and the fee is the only part of that with a line in the accounts.

The mistake to avoid

Optimising for the fee band rather than the outcome. Fee bands are a proxy, they are revised, and a pack designed to sit one point inside a threshold is a pack that will need redesigning when the threshold moves.

What we tell clients to do

Get the fee data into the same model as material, transport and waste cost, before choosing anything. One model, four numbers. Most organisations we work with have those four numbers in four departments, which is why the total is rarely calculated by anyone.