What are the practical strategies and service providers for managing EPR (Extended Producer Responsibility) compliance and costs?

EPR compliance is creating significant cost pressures for drinks brands, with some facing six or seven-figure annual impacts depending on sector. Members are using several practical approaches:

**Service Providers & Consultants** - **Ecosurery** (Bristol) — recommended by multiple members for managing EPR registration and compliance - **CLARITY** — a consultancy that has identified potential cost mitigation strategies and is helping brands develop collective responses

**Cost Mitigation Tactics** - **On-Trade exemption letters** — Some consultancies have identified a potential route to reduce costs: obtaining written confirmation from end-on-trade customers (not wholesalers) stating that bottles cannot be removed from the premises where sold. Members report most customers are willing to sign these letters. - **Collective industry approach** — Several members are forming a united group with competitor brands to submit appeals to DEFRA, though this takes time. A large soft drinks brand has already faced investigation for attempting to exclude on-trade from waste returns to avoid the levy.

**Key Caveats** - Retailers and wholesalers are responding inconsistently — some are collaborating with suppliers on costs, others are delaying decisions and leaving suppliers to fund the interim gap. - Amazon and other major online platforms have notified some sellers of EPR tax increases and requested price decreases; members report some suppliers are absorbing these rather than passing them on. - The on-trade letter strategy may face scrutiny (DEFRA has already investigated similar approaches by larger brands). - Joining a collective buying group or consultancy arrangement can help coordinate strategy but requires time investment.

Members advise monitoring DEFRA's response to appeals and collective challenges.