Warning over EPR’s impact on temperature-controlled packaging

HYDROPAC has said that businesses using temperature-controlled packaging may need to rethink long-established packaging choices.

The warning comes as the UK’s extended producer responsibility (EPR) regulations begin to change the commercial cost of different cooling materials.

Organisations with annual turnover above £1 million and handling more than 25 tonnes of packaging annually are now required to report packaging data, while businesses classified as ‘large producers’ – those with turnover above £2 million and handling more than 50 tonnes of packaging each year – are required to report packaging data, meet recycling obligations and pay EPR waste disposal fees.

While the regulations apply across multiple sectors, including food and drink, pharmaceuticals, meal kits, eCommerce and pet food, Hydropac believes one area receiving little attention is the impact on temperature-controlled packaging.

Under EPR, businesses may be required to fund the disposal of packaging that enters household waste streams. Crucially, the fees are based on the type and weight of material classified as packaging waste.

For organisations operating at large producer’ scale, this means packaging choice is no longer solely an operational or sustainability decision – it is increasingly becoming a financial one, Hydropac said.

Based on Hydropac’s analysis of the current EPR fee structure, a standard 500g water ice pack attracts disposal fees of around 0.55p per unit, as only the thin outer plastic film is classed as packaging.

By comparison, a standard 500g gel ice pack attracts fees of around 14.3p per unit, because both the plastic outer layer and the full weight of the gel contents are classified as chargeable material under EPR.

This creates an additional disposal-related cost of approximately 13.75p per gel packcompared with a water-based alternative.

When applied to packaging volumes typical of large producers, the financial impact becomes significant, it added. A business handling 50 tonnes of packaging annually could face around £13,750 in additional yearly costs when using gel ice packs compared with water-based alternatives. At 100 tonnes this increases to approximately £27,500, rising to £55,000 at 200 tonnes and more than £137,000 at 500 tonnes.

Unlike many compliance costs, Hydropac says this is one businesses can actively influence through their choice of packaging materials. The company also believes there remains considerable uncertainty around the practical implications of EPR.

Although reporting requirements have widened to include more businesses, many organisations still assume the regulations do not apply to them or are unclear about how packaging choices could affect future compliance costs as they grow.

Colin Rowland, Hydropac MD, said, “For years, we’ve been advocating for simpler, more sustainable cooling solutions, not just because they’re better for the environment, but because they make practical commercial sense.

“What’s changed is that EPR now places a measurable financial value on material choice. With gel packs, you’re paying to dispose of both the plastic and the gel contents. With water packs, it’s just the outer film. That difference is now directly reflected in the cost.

“Traditionally, businesses have specified cold-chain packaging based on thermal performance, reliability and purchase price. EPR introduces another consideration – the ongoing cost of disposal. Packaging decisions are becoming financial decisions.

“We’ve spoken to businesses that are still trying to understand whether EPR applies to them and what it means in practice. As reporting requirements expand, more organisations are now within scope, even if they’re not yet paying full EPR fees. Now is the time to understand those obligations and review packaging strategies before costs begin to escalate.”

Hydropac believes the regulations represent a significant shift in how packaging decisions are evaluated, moving sustainability from a purely environmental consideration to one with direct commercial consequences.

Colin continued,  “We’ve long believed water-based cooling solutions offer environmental advantages because they use simpler materials. What’s interesting is that the regulatory framework is now reinforcing that position commercially as well.

“Businesses are increasingly looking for ways to reduce costs without compromising product protection. For many organisations, reviewing their cold-chain packaging could become one of the simplest opportunities to do exactly that.”

Hydropac is encouraging businesses operating temperature-controlled supply chains to review both their EPR obligations and their packaging specifications as part of wider cost, compliance, and sustainability planning.