Methodology and procedure for calculating 2025 to 2026 payments
Updated 14 July 2025
This guidance should be read with the Notice of Assessment letter which was sent to each local authority (LA) in July 2025.
The Notice of Assessment letter sent to local authorities (LAs) in July outlines:
- the total Extended Producer Responsibility (EPR) for packaging payments PackUK anticipates making for the financial year 2025 to 2026
- when payments will be made
This guidance provides more detail on how this anticipated payment has been calculated.
Notice of Assessment letters provided in July 2025 relate to anticipated payments to be made in the financial year 2025 to 2026 only.
The payment amount shown in your Notice of Assessment letter reflects what PackUK (the scheme administrator) anticipates making your authority at this time, however your actual payment may still differ from this figure in some limited circumstances, including:
- in the event of a successful complaint or appeal from producers or LAs
- if PackUK does not receive sufficient funds from producers
Final payment amounts will be confirmed in your quarterly grant determination letters, which your authority will receive before each scheduled payment (please refer to your Notice of Assessment letter for the payment schedule).
PackUK may collect updated data and improve modelling methods used to assess payments in future years. This may contribute, along with other factors, to changes in the distribution and values of future payments to LAs. We anticipate updating this guidance on a yearly basis.
1. Scope of payments
This section provides a description of the costs that PackUK has accounted for in determining an LA’s payment. į
Under (the EPR for packaging regulations), PackUK (the scheme administrator) must assess LA EPR for packaging payments for 2025 to 2026, including:
-
Efficient disposal costs in total and for each packaging category - including all expenses relating to the proper disposal, recycling, or treatment of waste, ensuring it is done in an environmentally friendly and cost-effective manner. It also includes the costs of providing public information about the management of household packaging waste, including the costs associated with both the planning and the execution of any information campaigns.
-
Waste income from the expected sale of household packaging waste for each packaging category.
-
Net efficient disposal costs for each packaging category - this is calculated by considering the efficient disposal costs minus the expected income from the sale of household packaging waste.
-
Chargeable disposal costs - for the 2025 to 2026 assessment year, this will be the total net efficient disposal costs for all packaging categories.
Under regulation 70(6) of the EPR for packaging regulations, “efficient disposal costs” are disposal costs that an authority would incur providing an efficient waste management service. A relevant authority provides an efficient waste management service if the disposal costs of the authority are as low as reasonably possible, taking into account:
-
the waste management service provided by the LA į
-
any other factors specific to that LA, or to the area in relation to which it exercises its waste management functions, which in the opinion of PackUK are likely to affect its disposal costs
Efficient disposal costs include:
-
costs incurred for the collection (from kerbside, communal collections, bring sites and household waste recycling centres (HWRCs) where relevant)
-
costs incurred for the handling, sorting, treatment, and disposal of household packaging waste net of relevant income, including administration and communication costs such as the costs to the authority of providing public information about the management of household packaging waste, including the costs associated with planning and carrying out information campaigns
“Net efficient disposal costs” means the efficient disposal costs in an assessment year, less the expected income for that year from sale of household packaging waste.
2. Local Authority Packaging Cost and Performance Model (LAPCAP)
Costs LAs incur in the management of household packaging waste have been assessed using a model developed by Defra on behalf of the 4 UK nations. This model is called LAPCAP. LAPCAP calculates the net efficient waste management costs of managing household packaging waste for each individual LA.
The legislative requirements underpinning the development of the model are set out in the EPR for packaging regulations. In determining net efficient disposal costs for the 2025 to 2026 assessment year, LAPCAP may consider:
-
frequency, pattern and type of collections of household packaging waste in the area of that LA (“the relevant area”)
-
population density in the relevant area
-
type and accessibility of dwellings in the relevant area
-
levels of deprivation in the relevant area
-
government policies and the regulatory requirements affecting waste management to which the authority is subject
-
any other factor PackUK considers relevant to the assessment
The full legislative requirements for the assessment of LA costs, and therefore LAPCAP, are detailed in the EPR for packaging regulations. Currently LAPCAP does not include costs associated with business waste, street bin waste or litter, in accordance with those regulations.
Payments will cover the cost of the packaging element of the waste stream for eight high-level packaging material types.
The packaging categories set out in the EPR for packaging regulations are:
-
ܳԾܳ
-
ٱ
-
paper and card
-
پ
-
ɴǴǻ
-
fibre-based composite
-
other materials
Drinks containers made from polyethylene terephthalate (PET), steel, or aluminium between 150ml to 3l in size are excluded from EPR for packaging disposal fees until 2028. They will be in scope from 2028 only if a Deposit Return Scheme (DRS) is not in place by that time. Packaging collected in the food and garden waste streams are also excluded.
The following waste streams are included in LAPCAP:
-
dry recyclate collected commingled or separately from kerbside, bring sites or HWRCs including the packaging materials listed in the EPR for packaging regulations
-
residual waste including the packaging materials listed in the EPR for packaging regulations
If LAs provide dry recyclate offtake and residual waste treatment and disposal, the net efficient disposal costs calculation will include provision for a transfer station.
Tipping away payments
Tipping away payments apply when the County Council, acting as the Waste Disposal Authority (WDA), is unable to provide the District and Borough Councils, Waste Collection Authorities (WCA), with a suitable location to tip waste within a reasonable distance of the boundary of their area.
The LAPCAP model excludes provision for costs related to tipping away payments. In cases where a tipping away payment is necessary, the LAPCAP model assumes that the WDA will continue to make this payment. The LAPCAP model determines a WCA’s efficient costs. If the WCA has to transport waste further than reasonable, this would be deemed inefficient, and a tipping away payment from the WDA to the WCA is still justified.
3. LAPCAP methodology
This section describes how the model calculates the net efficient disposal costs EPR for packaging payment for each LA. į
LAPCAP uses a combination of LA-specific data and comparative data to calculate EPR for packaging payments for each LA in the UK. For example,
-
tonnes - reported in Waste Data Flow
-
comparative data - groupings based on reported cost data from a sample of LAs (more information on this is provided in the meta data section below)
LAPCAP’s methodology can be summarised in a simplified way [footnote 1] as follows:
Recylate collection cost + recyclate handling, sorting and transport costs - income from sales of recyclate
+
Residual collection cost + residual handling, sorting and transport costs + residual treatment and disposal + disposal overheads
= Net payment to LA
For WCAs and WDAs respectively disposal and collection costs are omitted where appropriate and an adjustment is made to account for recycling credits unless there is information that other local arrangements are in place.
More detail on how the model handles two tier authorities and recycling credits is provided in the separate sections below. į
The model is made up of 4 modules, which come together to produce output data. This output data is used in the calculation above to produce final outputs. The 4 modules are: į
-
meta data
-
waste flow
-
gate fees
-
cost per tonne
The meta data module
This provides the LA characteristics, such as:
-
Բ
-
dzܲԳٰ
-
type of LA
-
rurality level
-
deprivation level
-
household numbers by property type
-
collection system for every LA in the UK
This data is used as inputs to the other modules. More information on LA characteristics and on how these are used to group LAs when calculating waste collection costs is provided in the section below.
The waste flow module
The waste flow module converts LA reported data on movements of waste into the relevant packaging tonnages for the model. It draws on the web-based system used by UK LAs for municipal waste data reporting to government. The module uses tonnage data from combined with packaging waste composition data from the , and to estimate:
-
tonnages of packaging waste collected by each collection method, for example, from kerbside, bring sites and HWRCs
-
tonnages going to each disposal method
Scheme type refers to the collection of the material tonnage in the following service:
-
Commingled į
-
Multi-stream į
-
Two Stream
Scheme type data is based on WRAP LA portal data held for 2021 to 2022; this year has been used to align with the most recent audited tonnage data set available at the outset of the LAPCAP model build.
Understanding the collection schemes used by LAs is needed to accurately distribute tonnage based on scheme data.
In November 2024, LAs were given the opportunity to confirm their scheme type for the 2021 to 2022 period. Where applicable, the feedback has been incorporated to ensure consistency. Further updates will be applied for Year 2 of the EPR for packaging scheme.
This module provides all inputs on tonnages and movements of waste for the model. Where composition data is not sufficiently detailed, additional sources have been used including:
-
Data submitted by producers in the Report Packaging Data (RPD) system for 2024 – there are categories in the waste composition studies that contain indeterminate small amounts of in-scope wood, ‘other’ and fibre-based composite packaging. RPD data is used to determine the appropriate proportions here based on which values lead to alignment of in-model tonnages with these producer-reported tonnages.
-
The report for plastic is used to determine the proportion of PET bottles in England, Scotland, Wales and Northern Ireland that are excluded from EPR. This is applied to the WRAP 2017 data to split this category into in-scope and out-of-scope material. Before the implementation of DRS, the relevant exclusion from EPR for packaging payments in Year 1 applies specifically to drinks containers made from polyethylene terephthalate (PET), steel, or aluminium, ranging in size from 150ml to 3 litres. This exclusion remains in place until 2028. The waste composition study categories for steel and aluminium that is excluded on this basis are sufficiently detailed that we do not require additional data.
More information on data inputs is provided in Annex A.
The gate fees module
The gate fees module provides data on the cost per tonne to dispose of waste. It calculates net gate fees for each material type going to each facility type (cost per tonne of waste for each facility). For Material Recovery Facilities (MRFs), a different net gate fee is also calculated for each nation. Calculated gate fees include bulking, haulage and transfer costs. To calculate net gate fees (which are used in the final calculation) we first calculate gross gate fees and then net off income as described in the steps below. Average gate fees are used because it is not considered possible at this time to reliably model the factors influencing gate fees in different LAs.
In future we will explore introducing more sophisticated methodologies to more accurately model the different gate fees LAs pay. We also plan to adjust calculated gate fees to account for transfer and haulage costs differing between LAs.
Step 1: Calculating median gross gate fees for different disposal methods
For dry recyclate sent to MRFs, the gate fees module calculates a median gross gate fee for each nation. This uses data from the 2022 to 2023 for the costs of handling materials sent to MRFs.
For reprocessors, re-use, exporter re-use and exporter recycling the gate fees module calculates a single median gross gate fee for each material type. It uses data provided by Welsh Local Government Association (WLGA) and WIDP which is then applied to all LAs across the UK. All these disposal methods are assigned the same median gross gate fee for each material type due to data limitations.
Step 2: Accounting for income: calculating rebate values for each material going to each facility type
This section explains how we calculate a rebate value for each material at each facility type. A single rebate value is calculated for each facility type and material type and is then applied to all LAs across the UK. The rebate value is used to calculate net gate fees in the next step.
Income from the sale of dry recycling from MRFs, reprocessors, re-use, exporter re-use and exporter recycling is calculated by taking the difference between the median gross and median net gate fees and apportioning this rebate value across different materials. The median net gate fee in this case is the median of the reported gate fee from the same data sources mentioned above which were used to calculate the median gross date fee (WRAP gate fee survey, WLGA and WIDP). This is different from the calculated net gate fees which the module gives out as its main output.
For each facility type we use the difference between gross and net gate fees to determine a total rebate for all materials (for example, the rebate for a tonne of mixed recycling going to a MRF). We then calculate how much of this total rebate should be assigned to each material based on material prices from and tonnages of each material type going to each facility from the Waste Flow Module. Data from Lets Recycle are available on a month-by-month basis for several years. Prices from the financial year 2022 to 2023 are used to correspond to the gate fee data.
In summary, each EPR for packaging material category is assigned a per-tonne rebate value for each facility type that is then used to calculate costs for each relevant LA across the UK. For more information on this calculation please see the worked examples.
Calculating net gate fees using the rebate values
Net gate fees for each material for each facility type, and in each nation for MRFs (for example, plastic going to MRFs in Scotland or glass going to reprocessor anywhere in the UK) are calculated by taking the median gross gate fee for that facility type and subtracting the relevant rebate value (in this case rebate of plastic going to MRF in Scotland, rebate of glass going to reprocessor).
Disposal costs for each LA are then determined by multiplying the calculated net gate fees by material tonnages going to each facility from the Waste Flow Module.
For residual waste sent to all facility types, (such as energy from waste, mechanical biological treatment, landfill) the gate fee module calculates a median net gate fee for each facility type directly from the WRAP Gate Fee Survey. This median net gate is then multiplied by the material tonnages going to each facility from the Waste Flow module to determine disposal cost. This means that in practice (and in terms of impact on base fees) costs and any income from these facilities is just apportioned evenly across materials according to tonnage. Please refer to the worked examples annex for a detailed breakdown of how this is calculated.
Differences in cost per tonne figures between different LAs can be driven by differences in assumed waste composition going to each disposal method and the varying income from material sales based on these differences.
Although national compositions are used, we do make individual adjustments, for example where we know materials are collected separately. This can have an impact on cost per tonne figures for some disposal methods, including MRFs. For more information, please refer to the worked examples document.
An addition is made to all MRF gate fees (for sorting commingled streams and separately collected materials) to cover the additional cost of compliance with the following:
The additional payment relates to the day-to-day operational costs as estimated in the EPR for packaging impact assessment and increases to regulator fees.
Overhead costs
All LAs are paid the same per household overhead costs. These costs reflect the administration, contract management and other LA costs of managing waste disposal functions and HWRCs. Local communication campaign costs are also included.
Overheads are calculated on a per household basis and on the average cost per tonne per household. Data on household numbers comes from 2021 data from the () and (). We calculate a single per household cost using the data from the Request for Information (RFI) then multiply by the ONS and SNR household number estimates to get total overheads for each LA. The RFI is a survey sent to LAs to request information on the collection of up-to-date actual cost data of waste collection and disposal services, where relevant for the use of LAPCAP.
Overheads per tonne can differ between LAs due to the differences in the number of tonnes collected per household. If the average household in one LA generates more waste than the average household in another LA, the overhead per tonne will differ.
Overhead costs are not included in gate fees for HWRCs and treatment and disposal such as landfill, incineration, and energy from waste (EfW)[footnote 2] so are added to reflect the full LA cost of managing waste disposal functions.
Private Finance Initiative (PFI) contracts
PFI contracts involve LAs transferring the responsibility of financing and managing waste infrastructure, such as waste transfer stations, recycling centres, and EFW plants to private companies. LAs pay the private companies based on the performance and of the services provided over the contract period.
Where LAs with PFI contracts responded to WRAP’s Gate Fee survey, their data has been incorporated in the model. Therefore, these costs are reflected in the overall average figures used in the analysis. Data held by Defra and the Waste Infrastructure Delivery Programme (WIDP) relating to Mechanical Biological Treatment (MBT) gate fees has been included in gate fee costs.
Flexible Plastic Fund (FPF) FlexCollect Scheme
FlexCollect is a pilot project to test and refine methods for collecting and recycling flexible plastic packaging at the household level.
For those LAs known to be running a formal plastic film pilot as part of the FlexCollect UK scheme an additional payment has been made to cover the reported cost of operating the pilot in 2025 to 2026. The LAPCAP model outputs calculate LAs’ FlexCollect payment, this is included in the notice of assessment letter.
The cost per tonne module
The cost per tonne module calculates the efficient costs of collecting packaging waste for all LAs from:
-
recyclate and residual kerbside collections
-
bring sites
-
HWRCs
This module groups LAs to calculate cost per tonne figures for waste that is collected from each of these sources, reflecting the fact that collection costs vary depending on a LAs characteristics. The costs include:
-
front-line staff
-
vehicles (running costs, maintenance, fuel and annualised capital expenditure)
-
containers provided to householders (annual replacement and annualised capital expenditure)
-
overheads including management, admin, equipment, IT, local communication campaigns.
-
Capital expenditure, which is reflected in the cost-per-tonne values. It is annualised - for example, if an LA buys a vehicle with a five-year life expectancy, we attribute one fifth of the costs per year.
Cost per tonne figures for kerbside recyclate and residual collection are determined by using a grouping method. The grouping method creates 10 groups of LAs for residual collections and 10 groups for recycling collections. To create these groups, reported cost data[footnote 3] from a sample of 49 LAs from across the UK plus actual cost data from Welsh LAs, provided by the WLGA, analysed to identify the common characteristics which most strongly influence these collection costs. These characteristics are listed in the LA Groupings (residual and recycling) section of the guidance and examples of how this works can be viewed in the worked examples annex.
To group LAs expected to incur comparable costs per tonne of waste collected, the model uses:
-
findings from this analysis
-
legal requirements on the factors we must consider
-
data on LA characteristics from the meta data module
Calculating a cost per tonne
LAPCAP groups LAs according to their characteristics to create:
-
10 groups of LAs for recycling collections
-
10 groups of LAs for residual collections
More information on these is in the section LA groupings (residual and recycling). The average cost per tonne for sampled LAs in each group is used to determine cost per tonne figures for every group.
HWRC costs have been based on data provided by our sample WDAs plus the unitary authorities in the RFI sample. Our ambition is to obtain a wider sample in the future.
Due to limited RFI cost data available for HWRC and bring sites LAPCAP uses a method where the overall average cost per tonne across all LAs is applied.
4. LA groupings (residual and recycling[footnote 4])
The factors used to group LAs for kerbside recyclate collections are:
-
collection frequency – for example every week, fortnightly, 3-weekly
-
rurality (% urban) - rurality % based on highly rural, rural and urban
-
proportion of flats percentage of housing units in each area that are flats compared to other residential properties based on the 2021 ONS census and National Records for Scotland estimates
-
deprivation - proportion of Indices of Deprivation (IMD) band D&E (Lower layer Super Output Areas) LSOA areas in the authority
-
UK dzܲԳٰ
-
tonnes collected per household - calculated by LAPCAP to help determine LA waste collection groupings as the tonnes collected from the kerbside as dry recycling or residual waste
-
collection scheme proportion – the proportion of households served by each specific waste collection scheme for commingled, multi-stream and two-stream
-
food collection flag – a binary indicator, set to 1 if a LA has reported collecting waste through a dedicated food waste collection stream, and 0 otherwise
For kerbside residual collections this module uses the following factors to group LAs. The same definitions apply to these factors as above:
-
collection frequency
-
rurality (% urban)
-
proportion of flats
-
deprivation
-
country
-
tonnes collected per household
-
garden collection flag – a binary indicator, set to 1 if a LA has reported collecting waste through a dedicated garden waste collection stream, and 0 otherwise
-
bring site flag – a binary indicator, set to 1 if a LA has reported collecting waste through bring sites, and 0 otherwise
Authorities are grouped by finding their closest comparators for each of these variables. LAs are placed in groups with other LAs that share the most similarities across the factors[footnote 5]. į
Rurality and Deprivation
LAs are assigned to a rurality deprivation group, a dry recycling group and a residual group. The cost per tonne for each stream is based on the group the LA is in. More information on this is provided in the LA Groupings section.
Household numbers
Household numbers are used in 2 ways in the model:
-
to determine overheads
-
to group LAs for collection costs
Data on numbers of households is from the:
-
for England and Wales
-
for Scotland
-
for Northern Ireland
These datasets will be kept under review to ensure LAPCAP includes the best possible data.
To determine overheads the cost per household comes from the RFIs supplied by LAs with disposal functions, for example Unitary authorities and WDAs. These overheads also include the costs for managing HWRCs and bring sites. Cost per household is then multiplied by numbers of households in each LA.
When grouping LAs for collection costs, 3 factors use household data:
-
Proportion of flats which uses 2021 council stock data for England.
-
Proportion of communal collections which use regarding the number of households served.
-
Tonnes per household which uses regarding the number of households served.
Although household data comes from different sources, this data is the most consistent and best available data.
Due to the difference in cost drivers between dry recycling and residual waste, a single LA can be in one group for its dry recycling collections and bring sites and another group for residual and HWRCs.
Statutory Joint Waste Disposal Authorities (SJWDAs) and county councils
SJWDAs and county councils don’t appear in LA groupings because these groupings are only used to determine collection costs. We do not currently have an equivalent grouping method for disposal costs due to the variety of different factors that drive these costs and limited data on these factors.
Changes to groupings in future years
Collection cost groupings are something that we plan to recalculate each year of EPR for packaging. For example, if an LA’s grouping characteristics change from year 1, this could mean the LA moves groups when groupings are recalculated.
Due to the nature of the analysis, changes in the characteristics of some LAs could affect the grouping of others, even if those authorities’ characteristics have not changed themselves. The cost per tonne for each stream is based on the relevant group the LA is in.
A table showing the groups that each LA is in is provided in Annex B.
5. Bringing it all together – calculating the final output
Several functions combine the outputs of the 4 modules to produce the final outputs. For instance, gate fees are combined with disposal tonnages to calculate disposal costs. These costs are then provided as outputs split by various factors, including waste stream, packaging category and LA.
More information on this can be found in the worked examples annex but the following figure and explanatory text provide a summary[footnote 6] of how outputs from the 4 modules come together:
Recylate collection cost + recyclate handling, sorting and transport costs - income from sales of recyclate
+
Residual collection cost + residual handling, sorting and transport costs + residual treatment and disposal + disposal overheads
= Net payment to LA
The cost per tonne module gives estimated kerbside, HWRC and bring site collection costs per tonne of residual and recycling waste for each LA. These outputs are then combined with tonnages from the waste flow module to calculate the:
-
dry recycling kerbside collection cost
-
residual kerbside collection cost
-
HWRC collection cost and bring site collection cost
This is done for each packaging category material and for the total collection costs across all household packaging waste.
For dry recycling kerbside collection costs, the impact that volume has on collection costs is taken into account.
This is done in the following way:
-
Multiplying the cost per tonne figure (provided by the cost per tonne module) by the total tonnage each LA manages in dry recycling kerbside collections.
-
This calculates the total cost of collecting dry recyclate (packaging and all other waste).
-
This total cost is then apportioned across materials based on the proportion of each material by volume.
-
The estimated volume of each material in the dry recycling stream is calculated through the tonnage and a corresponding bulk density value (data provided by WRAP and supported by the data collected in the Bulk Density Factors Desk Review 2022). More information on this can be found in Annex C.
-
Volume apportionment is applied across all materials (both in scope and out of scope) as all materials are collected from the same collection vehicles.
Therefore, the calculated volume of out-of-scope materials directly affects the cost apportionment of EPR for packaging materials. For example, if a given LA collects a large amount of low-density non-packaging in their dry recycling stream, this will mean a lower proportion of collection costs are allocated to higher-density packaging materials. This adjustment recognises that volume is commonly the limiting factor in dry recycling collections.
Dry recycling composition varies between LAs due to various factors, such as:
-
type of recycling collection scheme
-
what materials are recycled
-
demographic
The data we use comes from Waste Data Flow therefore the information provided impacts varying factors. This can mean that the subsequent collection cost per tonne for kerbside dry recycling can vary even for LAs within the same group.
Costs are inflated to the desired year using the Office for Budget Responsibility (OBR) Retail Prices Index (RPI) inflation forecasts.
Residual handling, sorting, and transport costs and residual treatment and disposal costs are calculated using the:
-
national UK average net gate fees for the different disposal methods from the gate fees module
-
tonnages for each packaging category material from the waste flow module
The handling, sorting and transport net of income of dry recyclate is calculated using the gross gate fee[footnote 7] and material specific rebate[footnote 8] taken from the Gate Fee Module as a cost per tonne. This is multiplied by the tonnage for each packaging category taken from the Waste Flow Module. The gross cost and adjustment for income is shown in your notice of assessment letter.
Disposal overheads have been determined by multiplying the average disposal overhead costs per household (taken from real cost data from a representative sample of 32 LAs from across the UK) by the numbers of households in each LA.
These overhead costs reflect the administration, contract management and other LA costs of managing waste disposal functions.
Data on the number of households is from the:
-
for England and Wales
-
estimates from 2021 for Scotland
-
for Northern Ireland
6. Allocation of Costs Across Two Tier Authorities (England only)
Costs for different household packaging waste management services are allocated in the model across two tier authorities according to the table below. This follows relevant legislation which assign responsibility for delivery of these services. A tick indicates that costs for the corresponding service are included in the payment assessment for that type of LA.
Table of costs for different packaging waste management services are allocated in the model across two tier authorities
LA Cost | Unitary | WCA | WDA | Statutory Joint Waste Partnership WCA | Statutory Joint Waste Partnership WDA |
---|---|---|---|---|---|
Collection of dry recycling from kerbside | Yes | Yes | No | Yes | No |
Collection of residual waste from kerbside | Yes | Yes | No | Yes | No |
Bring Sites | Yes | Yes | No | Yes | No |
Collection of dry recycling from HWRC | Yes | No | Yes | No | Yes |
Collection of residual from HWRC | Yes | No | Yes | No | Yes |
Transfer stations/bulking and haulage of Recyclate | Yes | No | Yes | No | Yes |
Transfer stations/bulking and haulage of Residual | Yes | No | Yes | No | Yes |
Tipping Away Payment | n/a | No | No | No | No |
Handing and Sorting of Recyclate | Yes | No(unless we have information that the WCA has taken responsibility) | Yes(unless we have information that the WCA has taken responsibility) | No | Yes |
Income from Recyclate netted off | Yes | No(unless we have information that the WCA has taken responsibility) | Yes(unless we have information that the WCA has taken responsibility) | No | Yes |
Treatment and disposal of residual waste | Yes | No | Yes | No | Yes |
Recycling Credit | n/a | No (Value of credit payment to WDA netted off total WCA payment) | Yes(Where known to pay credits to WCA) | No | No |
Other Interauthority Payment for waste | n/a | No | No | No | No |
7. Adjustments for Recycling Credits (England only)
The Environmental Protection Act 1990 requires WDAs to pay waste recycling credit payments to a WCAs in its area when the WCA retains waste for recycling.
The scheme seeks to ensure that any savings from the reduced waste disposal costs for a WDA (when waste is recycled) are shared with the relevant WCA, and in so doing incentivise recycling for WCAs.
Unless otherwise agreed[footnote 9], WDAs are obliged to pay recycling credits where claimed by the WCA. The WDA must pay the WCA its net saving of expenditure. Where this value is not known the [footnote 10] provide a default value with a 3% indexation. į
A payment of a recycling credit by a WDA falls under the definition of “disposal costs” for the purposes of EPR for packaging and has therefore been included in the assessments of costs. It is also important that producers are not double charged for waste management activities. If a WDA receives the disposal costs from PackUK to account for the recycling credits paid to the WCA, the WCA cannot claim the cost of recycling that material as part of its own disposal costs.
Based on the above, LAPCAP:
-
pays WDAs to cover the cost of recycling credits for household packaging waste where the WDA is known to pay their WCAs inter-authority payments relating to recycling. į
-
pays no recycling credits to WDAs and Statutory Joint Waste Disposal Authorities where it is known that no recycling credits or similar arrangements are in place į
If recycling credits are paid to a WDA this has been calculated using the method set out in (using the default payment values set out in the Schedule to the Regulations). į
Contact PackUK if you have been allocated a payment for recycling credits, or if one is netted off your payment, and you either:
-
have no arrangements for paying or receiving a credit but have an adjustment in your notice of assessment letter
-
pay recycling credits and don’t have an adjustment in your notice of assessment letter.
Adjustments for recycling credits will not apply for Statutory Joint Waste Disposal Authorities and Statutory Joint Waste Collection Authorities.
Calculating recycling credits
Recycling credits are paid for every tonne of household packaging waste collected in the dry recycling scheme. For an example of how recycling credits are calculated in the model please refer to the worked example annex.
8. Sampled LA Cost Data - Data Collection
In 2023, Defra (supported by 4 contractors) contacted 110 LAs to request comprehensive cost information regarding their waste services so that this data could contribute to the build of the LAPCAP model for year 1.
To ensure as wide and diverse a range as possible, all UK Waste Collection LAs were put into one of ten socio-demographic groupings. Additionally, they were further separated based on their dry recycling system and the frequency of their residual collections, creating a total of sixty-seven sub-groups for sampling. The table in Annex E displays the number of LAs in each group. į
Representative (‘request for information’) RFI samples were selected from across the groups. Where an LA could not provide data, an alternative similar LA was approached instead.
All data that was collected and provided was quality assured to ensure accuracy and relevance to the model. į
This process generated 52 LA datasets of suitable quality to use in the model. Of these RFIs
-
40 are from England
-
2 from Northern Ireland
-
5 from Scotland
-
5 from Wales
-
19 from WCAs
-
28 from Unitary Authorities
-
5 from WDAs
The following list shows LA’s that provided RFI data: į
- Armagh Banbridge Craigavon
- Basingstoke
- Blackburn
- Belfast
- Calderdale
- Cheltenham
- Conway
- Cornwall
- Derbyshire
- Dover
- Dudley
- East Hertfordshire
- East Renfrewshire
- East Riding
- Edinburgh
- Fareham
- Hackney
- Haringey
- Harrogate
- Huntingdon
- Isle of Scilly
- Isle of Wight
- Kirklees
- Leeds
- Maldon
- Neath Port Talbot
- Newham
- Newcastle Upon Tyne
- Norfolk
- North Ayrshire
- North East Lincolnshire
- North West Leicestershire
- North Yorkshire
- Plymouth
- Powys
- Oldham
- Orkney
- Oxfordshire
- Pembrokeshire
- Redcar and Cleveland
- Rhondda Cynon Taf
- Rotherham
- Sevenoaks
- South Ayrshire
- Stockton-on-Tees
- Surrey
- Thurrock
- Wandsworth
- Westminster
- Worthing
- Wyre
9. Model quality assurance
There are robust processes in place for quality assuring (QA) LAPCAP. This has included close working with the Government Actuary’s Department (GAD) to help develop our overall QA process and undertake model verification. All outputs were checked against the LA sample data as well as other data sets such as RO5[footnote 11] and data held by the Welsh government. į
GAD has completed an initial independent verification review of the model which focused on whether implemented calculations:
-
are consistent with the documented methodology
-
are free from error
-
use a logical structure
-
adhere to best practice
The review included the following elements:
-
Testing of the model code and underlying functions.
-
Input and output testing – inputs and outputs have both been provided by Defra, and these have been run through the model to test reproducibility of the results. A detailed code review – all areas of the model that are in scope have been examined thoroughly as part of a “line by line” review. This is intended to identify whether the code meets the specification, is free from error, uses a logical structure, is commented appropriately, and adheres to best practice. į
-
Independent testing – generating outputs from a completely independent model can provide assurance on the fitness for purpose of the model under review. Results for similar scenarios would be expected to agree within a tolerance based on appropriate judgement.
-
Assessing suitability of model documentation for understanding model implementation.
GAD’s findings, based on the scope of GAD’s review, show:
-
the model runs without error
-
results are reproduceable
-
they were able to test and independently replicate results
The findings also show room for improvements in our QA process. We have acted upon this feedback and GAD have indicated that since then our QA processes have improved substantially. We have further implemented retro-active QA through regression testing on earlier versions of the model.
GAD’s verification review is based on the model at a point in time and did not cover all aspects of the model.
GAD’s role in verifying the model is not to provide sign off that the model is fully quality assured and fit for purpose, the responsibility for this sits with PackUK.
9. Future Updates
PackUK will continue to ensure that the model uses the most up to date and representative data.
In future the EPR for packaging digital service will support LA data submission and validation and we are working on how this can best facilitate efficient data processing.
From 1 October 2024, more materials facilities will need to sample and report their waste and sampling and reporting will be more detailed and frequent. This will provide additional data, particularly on composition, that we anticipate the model will be able to use.
10. Efficiency and Effectiveness
Under the EPR for packaging regulations an authority provides an efficient waste management service if the costs of this service are as low as reasonably possible, taking into account: į
-
the waste management service provided by the authority
-
any other factor specific to that authority, or to the area to which it exercises its waste management functions, which in the opinion of PackUK are likely to affect its disposal costs
Using data received through RFIs and other data sources LAs can be grouped according to similarity of both service provision and local characteristics. PackUK is able to estimate, through averages, what level of expenditure is reasonable for LAs in those groups to provide a waste management service for household packaging.
This metric is deemed the lowest reasonable cost for that group.
Effectiveness assessments will not be held in the first year of EPR for packaging.
Regulation 73 of the EPR for packaging regulations also requires PackUK to carry out its assessments in such a way as to incentivise good environmental outcomes.
By having tonnage-based fees, it incentivises producers to reduce the weight of packaging they put on the market. By not applying a second charge to reused packaging, the system encourages reuse, which helps reduce the amount of packaging that ends up as waste. By netting off an average material value in the LAPCAP calculations, the system rewards higher-quality materials that are more valuable as recyclate.
11. Modulation į
Disposal fees paid by producers (but not LA payments) may change as a result of modulation coming into effect in year 2 of EPR for packaging (2026 to 2027) which will further incentivise sustainable packaging decisions and drive recycling rates. The types of packaging which will be subject to higher or lower modulated household packaging waste disposal fees will be based on recyclability assessments in line with the recently published Recyclability Assessment Methodology (RAM).
The details of the modulation approach are subject to further design and industry engagement. Changes to disposal fees as a result of modulation will not impact the amount paid to LAs.
12. Complaints and Appeals
Complaints
If you have a complaint about the way we operate or the services we provide, please follow PackUK’s complaints procedure.
Appeals
We understand that there may be an occasion where you wish to appeal against a decision that was made by PackUK. Before you can appeal, you must have first brought a complaint under PackUK’s complaints procedure.
If new information or data becomes available relating to your original complaint you may ask for a reconsideration.
Check PackUK’s appeals procedure for more details on how to make an appeal.
-
Recyclatecollection cost includes collection overheads, these come from the Request for Information (RFI) data provided by LAs.Recovery income is reflected in the gate fees module.↩
-
This is because the gate fees survey captures the cost incurred at the time of using the facility but does not account for the operational costs of running the facility.↩
-
from RFI data↩
-
The groupings overall (residual and recycling together) account for89%of the cost per tonne variance of our sampled cost data by using those factors.↩
-
Local authorities are grouped using aconsensus K-means algorithm, which places each authority into a group based onit’ssimilarity to other authorities acrossall ofthe listed variables.This procedure is done multipletimesand an aggregated group is found.Authorities that share a group do not strictly share identical attributes, but will be moresimilar tothose it shares a group with, than with the authorities in other groups↩
-
Recyclatecollection cost includes collection overheads, these come from the Request for Information (RFI) data provided by LAs. Recovery income is reflected in the gate fees module↩
-
from WRAP 2021 to 2022↩
-
FromLetsRecycle data↩
-
(s52(1B) EPA)↩
-
Paragraph 3(6)↩
-
RO5 is a category of local authority spending that includes various services, including environmental and regulatory functions↩