Comply Direct respond to four packaging consultations

On 13 May 2019 Comply Direct sent off finalised responses to the DEFRA consultations on EPR Reform, Deposit Return Schemes and Consistency in Collections. Our response to the Treasury’s Plastic Tax consultation was sent on 10 May as it closed on 12 May 2019

During the 12-week consultation period from February to May, we had very high engagement levels with the webinars we delivered covering the consultations on DRS, PRN reform, plastic tax and UK recycling consistency, as well as a record response to our member survey which gathered views regarding the consultation on reforming the UK packaging producer responsibility system specifically.

Our final consultation responses consisted of over 34,000 words of content. This included in excess of 3,400 words of specific (anonymised) Comply Direct member feedback on the EPR consultation. We had contributions to our response from over 18% of our total member base. The combined obligation of members we included in our response made up approximately 5% of the UK’s total packaging obligation.

This is the most successful member engagement project for Comply Direct to-date and we are very grateful for all of the input from customers over the consultation period.

We have saved our final response documents to all four consultations in the member area of our website and members are invited to view them. To access the responses, please can members login to their online account here - then navigate to 'The Resource Room'. Once on this page, click 'Packaging Resources' from the right-hand side menu and scroll down to the header 'Comply Direct consultation responses - May 2019'. Please contact us at if you have any problems locating these documents.

In addition, Comply Direct also provided input to the responses submitted by the Packaging Scheme Forum (PSF). Comply Direct are a member of the PSF and you can find out more about our involvement with the forum here

Comply Direct Enhanced Market Hybrid Model

Having reviewed the 4 alternative models extensively, we believe there is still scope for an additional model which combines some of the benefits of the competitive market and centralised oversight of Local Authorities. We see value in a competitive market as it drives incentives to increase efficiency (both in terms of cost and emissions). We also support a system whereby producers are able to see the benefits of the fees they pay at the latter end of the supply chain, by supporting UK re-processors to develop innovative methods to recycle problematic packaging items. Whilst we do support the addition of a central body for oversight, we believe this is best achieved as a monitoring body which arranges the payment of producer funds to Local authorities, rather than a full compliance management body.

We have included a model of our hybrid system below, but if you would like further information, please do not hesitate to get in touch -

What next?

The government are set to respond in around 3 months’ time, however, the debate on the future of the UK’s waste framework will remain live in the interim.

Comply Direct will continue to hold member webinars / run podcasts and engagement events in the meantime but are also looking to create a Member Feedback Group specific to policy issues.

This feedback group is voluntary but any members whom wish to join will have access to a range of advisory and informative services such as bespoke webinars / training / discussions surveys and more.

If you would like to join our member feedback group please email, or feel free to put a request in with your Account Manager to add you to the group.

If you are not a member of our scheme and have any other queries regarding the consultations, please feel free to contact