Ask Our Experts
Welcome to our FourSights Q&A series, where leaders from across the FourCentric group share practical perspectives on the trends reshaping their industries. In this edition, Procure4’s CEO Chris Mullen and VP Client Solutions Adam Bateson answer a key question on many procurement leaders’ minds.
Q: How are new Extended Producer Responsibility (EPR)laws changing the priorities, costs, and decisions for procurement teams on both sides of the Atlantic?
Extended Producer Responsibility (EPR) laws are reshaping how businesses think about the lifecycle of the products and packaging they put on the market. Under EPR, producers are legally responsible not only for manufacturing and selling goods but also for what happens after use, from collection to recycling or disposal.
For procurement teams, this is a significant shift. The materials, suppliers, and design choices made today directly influence future compliance costs and environmental performance.
The UK and EU: Cost and accountability shifts
The UK’s new EPR for Packaging has introduced a major change in financial responsibility. Producers must now cover the full net cost of collecting, sorting, and recycling packaging waste. This replaces the partial recovery system under the old PRN scheme and represents a substantial uplift in producer costs.
For non-compliance, UK regulators can issue civil penalties of up to £5,000 per offence, along with enforcement notices and public disclosure. For many brands, the reputational impact is often more damaging than the fine itself.
Across the EU, EPR sits within broader sustainability legislation such as the Circular Economy Action Plan and the Corporate Sustainability Reporting Directive (CSRD). Procurement teams are now expected to ensure supplier transparency, manage end-of-life costs, and align sourcing decisions with corporate emissions and waste targets.
A closer look at the UK retail impact
The new regulations are already influencing procurement decisions across retail and FMCG. The combined effect of EPR charges and the Plastic Packaging Tax is significant. Retailers are reporting major annual cost increases, with John Lewis estimating an additional £22M and M&S around £40M. These pressures are accelerating shifts in packaging design, material choices, and supplier collaboration.
Procurement teams now need more detailed packaging data, including recyclability assessments from late 2025, adding further complexity. This is speeding up adoption of mono-material formats, higher recycled content, and earlier engagement with suppliers to manage both cost and compliance.
The US: Patchwork regulation and rising complexity
The US is seeing a patchwork of state-level EPR laws rather than a unified federal approach. Maine, Oregon, Colorado, and California have already enacted packaging EPR legislation, with more states expected to follow. Each has different requirements for producer registration, reporting, and fee structures based on packaging type and recyclability.
This fragmentation is creating both compliance complexity and a growing cost–benefit calculation. Some companies are weighing the cost of meeting state-specific requirements against the potential cost of fines and reputational risk.
While penalties vary by state, non-compliance can lead to civil fines, exclusion from state-run programmes, and public disclosure—a concern for brands operating under increased scrutiny around environmental claims.
For procurement teams, this means:
- Managing multiple, evolving state regulations
- Tracking data on materials, suppliers, and post-consumer recyclability
- Factoring compliance costs into total cost of ownership, not just purchase price
Why procurement’s role is central
EPR compliance can’t sit solely with sustainability teams or finance. Procurement influences the decisions—supplier selection, specifications, and contract terms—that determine a company’s exposure and its ability to lead on circularity.
Strengthening supplier relationships, improving packaging data visibility, and building recyclability and waste reduction into sourcing criteria will all help organisations manage EPR risk and turn compliance into advantage.
At Procure4, we help organisations build smarter, more resilient supply chains. As EPR expands across markets, the ability to integrate sustainability and compliance into everyday procurement decisions will define who stays ahead.