Table of Contents
- Biodegradable Packaging and EPR
- Common Misconceptions
- How Biodegradable Packaging Is Classified
- EPR Fee Rates
- Types of Biodegradable Packaging
- The Recycling Problem
- Practical Guidance
- Key Takeaways
Key Takeaways
- Biodegradable packaging is NOT exempt from EPR — it must be reported and fees must be paid like any other packaging material.
- Biodegradable plastics may attract HIGHER EPR fees than conventional recyclable plastics because they contaminate recycling streams.
- “Biodegradable” does not mean “compostable” — and neither term means “recyclable” in the EPR context.
- DEFRA guidance discourages biodegradable plastics in packaging because they are incompatible with current UK recycling infrastructure.
- Businesses switching to biodegradable packaging to “go green” may face higher EPR costs, not lower.
Biodegradable Packaging and EPR
Many businesses assume that biodegradable packaging is more favourably treated under EPR, or even exempt. This is not the case. Under UK packaging EPR, biodegradable packaging is subject to the same obligations as all other packaging: registration, data reporting, and fee payment.
In fact, the EPR regime may penalise biodegradable packaging more heavily than conventional recyclable materials, because biodegradable plastics can contaminate recycling streams and are not compatible with the UK’s existing collection and recycling infrastructure.
For EPR fundamentals, see what packaging EPR is.
Common Misconceptions
Misconception 1: “Biodegradable = No EPR Obligation”
Wrong. All packaging placed on the UK market is subject to EPR, regardless of its end-of-life properties.
Misconception 2: “Biodegradable = Lower Fees”
Not necessarily. Fees are based on recyclability, not biodegradability. Packaging that cannot be recycled through existing systems — including most biodegradable plastics — may attract higher fees.
Misconception 3: “Biodegradable = Compostable”
These are different things. “Biodegradable” means the material will break down eventually (no timeframe or conditions specified). “Compostable” means it will break down within a specific timeframe under specific conditions (usually industrial composting).
Misconception 4: “Customers Will Compost It”
Unlikely. Very few UK consumers have access to industrial composting. Home composting conditions rarely reach the temperatures needed for certified compostable packaging. Most biodegradable packaging ends up in landfill or contaminating recycling streams.
How Biodegradable Packaging Is Classified
Under EPR, biodegradable packaging is classified by its base material, not by its end-of-life properties:
| Material | EPR Classification |
|---|---|
| PLA (polylactic acid) | Plastic |
| PBAT | Plastic |
| Starch-based bioplastic | Plastic |
| Cellulose film | Plastic (if non-separable from coating) |
| Paper with biodegradable coating | Fibre-composite or paper |
| Bagasse (sugarcane fibre) | Paper/fibre |
| Palm leaf | Other natural fibre |
Key point: PLA and other bioplastics are classified as plastic under EPR, not as a separate “biodegradable” category. They attract plastic fee rates.
EPR Fee Rates
| Biodegradable Material | EPR Classification | Fee per tonne (approx.) |
|---|---|---|
| PLA packaging | Plastic (non-recyclable) | £420-£461 |
| PBAT packaging | Plastic (non-recyclable) | £420-£461 |
| Starch-based packaging | Plastic (non-recyclable) | £420-£461 |
| Bagasse containers | Paper/fibre | £215 |
| Paper-based compostable | Paper or fibre-composite | £215-£461 |
| Cellulose film | Plastic | £360-£461 |
PLA and other bioplastics typically attract the highest plastic fee rates because they are not recyclable through conventional systems and contaminate PET recycling streams.
Compare this with recyclable conventional plastics: clear PET at £340/tonne or HDPE at £340/tonne. Switching from recyclable PET to “biodegradable” PLA could increase your EPR costs.
For all rates, see the EPR fees by material type guide.
Types of Biodegradable Packaging
PLA (Polylactic Acid)
- Made from corn starch or sugarcane
- Looks like PET plastic
- NOT compatible with PET recycling
- Requires industrial composting (60+ degrees C)
- Classified as plastic under EPR
PBAT
- Petroleum-based but biodegradable
- Used in films and bags
- NOT recyclable
- Classified as plastic under EPR
Starch-Based Bioplastics
- Various formulations
- Limited barrier properties
- NOT compatible with existing recycling
- Classified as plastic under EPR
Bagasse (Sugarcane Fibre)
- Natural fibre material
- Used for takeaway containers, plates
- Classified as paper/fibre under EPR — lower fee rate
- Can be industrially composted
Paper-Based Compostable
- Paper with biodegradable coatings (PLA or wax)
- May classify as fibre-composite if coating is inseparable
- Higher fee rate than uncoated paper
The Recycling Problem
The fundamental issue with biodegradable plastics under EPR is that the UK does not have the infrastructure to handle them:
- No separate collection — councils do not collect biodegradable packaging separately
- Contamination risk — PLA in PET recycling streams ruins the output
- Limited composting capacity — few industrial composting facilities accept packaging
- Consumer confusion — people put biodegradable packaging in recycling bins, contaminating the stream
DEFRA has explicitly stated that biodegradable plastics are not a preferred solution for the UK packaging system. The priority is recyclable packaging that works with existing infrastructure.
Practical Guidance
If You Currently Use Biodegradable Packaging
- Calculate your actual EPR costs — they may be higher than you expect
- Consider switching to recyclable alternatives — recyclable conventional plastics or paper may be cheaper under EPR
- If you stay with biodegradable, report it correctly as plastic packaging
- Do not claim environmental benefits that are not supported by the actual disposal infrastructure
If You Are Considering Switching to Biodegradable
- Check the EPR fee impact — it may cost more, not less
- Evaluate recyclable alternatives first — mono-material recyclable packaging is favoured by EPR
- Consider paper-based options — bagasse and uncoated paper attract the lowest fees
- Verify customer disposal routes — will your packaging actually be composted?
Better Alternatives for EPR
| Instead of… | Consider… | EPR Benefit |
|---|---|---|
| PLA cups | Paper cups (unlined) | £215/t vs £461/t |
| PLA food containers | Bagasse containers | £215/t vs £461/t |
| Biodegradable bags | Recyclable PE bags | £360/t vs £461/t |
| PLA cutlery wraps | Paper wraps | £215/t vs £461/t |
Labelling Considerations
From 2027, packaging must carry mandatory recyclability labels. Biodegradable packaging that is NOT recyclable or compostable through collected streams will need to be labelled accordingly — potentially as “Do Not Recycle”, which is not a great look for packaging marketed as eco-friendly.
Getting Started
- Audit your biodegradable packaging and classify correctly under EPR
- Calculate the true EPR cost including potential contamination penalties
- Compare with recyclable alternatives on both cost and environmental grounds
- Make data-driven decisions about packaging material choices
Use the EPR fee calculator and see the glossary for material definitions.