On 19 December, the EA published both an updated set of numbers for 2023 and the data for the first half of 2024 (H1). The initial 2023 November release was greeted with wide scepticism due to some higher-than-expected volumes which, on the back of low Q4 recycling expectations, created the expectation of an extremely difficult 2025 for plastic and glass PRNs in particular.
The latest release has changed all that. The revised 2023 data is down to more realistic levels and the H1 2024 data is lower still. Of course, this could be because there is significant tonnage still to be registered, but it seems more likely that the potential waste fee costs have led to obligated companies taking a long hard look at their numbers.
| Aluminium | Glass | Other | Paper / Card | Plastic | Steel | Wood | Total | |
| H1 2023 total | 117,435 | 1,121,902 | 6,312 | 2,591,351 | 1,066,070 | 228,830 | 1,193,806 | 6,325,706 |
| H1 2024 total | 126,782 | 988,026 | 7,135 | 1,999,012 | 896,043 | 182,776 | 388,644 | 4,588,420 |
The consequence of these changes is that instead of 2025 targets looking tight for plastic and glass melt in particular, recycling at 2024 levels will see a significant surplus of PRNs and likely collapse in PRN prices across the board, both for 2024 carry forward and for 2025.
December also saw the latest illustrative waste fees for 2025. Applying these to the H1 2024 household non-DRS and bin tonnage – assuming at this stage that all glass will be out of DRS – gives a total £850m suggesting that 2025 will far exceed the £1,1bn that has been widely put about – unless the final waste fee figures are reduced significantly.
| Aluminium | Glass | Other | Paper / Card | Plastic | Steel | Wood | ||
| 19/12/24 Base fees/tonne | £435 | £240 | £215 | £485 | £305 | £320 | £280 | Total |
| 2024 H1 total | £9,351,595 | £225,827,238 | £1,065,471 | £400,741,637 | £174,936,779 | £38,976,283 | £2,312,042 | £853,211,046 |
Much of this uncertainty must be laid at the door of the EPR data system, RPD. Rumoured to be costing around £25m, the system has many problems, not least of which are the complexities of how the data must be presented. Very little thought seems to have been given to the users, whether producers or the regulators and there must be concerns as to how this will affect data accuracy and ultimately, how costs will be shared. For 2025 data, adding to the existing confusion will be the Recyclability Assessment Methodology (RAM) that producers of household packaging will have to consider. All of this adds staff cost on top of the increased registration and compliance scheme fees.