April 2026: Welsh Government Consultation: Amendments to Extended Producer Responsibility for Packaging to Cover Street Binned and Littered Packaging Waste.

The AVA strongly opposes the proposal to extend Extended Producer Responsibility (EPR) in Wales to cover littered and street‑binned packaging. We argued that this will fundamentally misallocate responsibility for illegal behaviour, undermine the polluter‑pays principle, and risk double or triple charging producers for the same material. We contend that littering should be addressed through existing enforcement powers against individuals, not by shifting costs onto compliant businesses, and that packaging correctly placed in public bins is not litter and is already funded through public services.

We highlighted that vending packaging is largely consumed in controlled environments and is wrongly captured by broad, proxy‑based fee models that ignore real‑world usage patterns. Our response considered all proposed fee options unworkable, disproportionate, and based on incomplete or immature data, with nation‑of‑sale reporting and the Regulatory Impact Assessment significantly understating complexity and risk. Overall, the AVA deems the proposal unworkable and unjustified, though we have suggested limited harm‑reduction alternatives solely to mitigate damage should the policy proceed despite our objections.

The AVA Response can be found HERE