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The 2026 regulatory wave - the infrastructure gap standing between ambition and delivery

EPR, Simpler Recycling and digital waste tracking are individually sensible policies, but the pace and concurrency are exposing an infrastructure gap the sector cannot afford to ignore, writes Marcus Brew, Managing Director at UNTHA UK

Marcus Brew, managing director at UNTHA UK
© Untha UK
Marcus Brew | 12 June 2026

The UK waste and resource management industry is navigating one of its most demanding years in recent memory - three major regulatory changes converging at once, in a sector already stretched by five years of sustained cost pressure, volatile markets, and a persistent skills gap.

Tightened Extended Producer Responsibility (EPR) rules took full effect in January, Simpler Recycling came into force for households in March, and mandatory digital waste tracking arrives in October. While each of these has received reasonable coverage and discussion individually, what isn't being discussed honestly enough is the cumulative effect on the sector's infrastructure.

The gap between regulatory ambition and operational readiness is real and widening - and the longer it goes unacknowledged, the more costly the consequences become.

Regulation at plant level

EPR changes the economics of the entire packaging supply chain - but its operational implications for waste processors are still working their way through the system. The shift of compliance costs onto producers is driving a trend towards consolidation, with investment gravitating towards larger 'super hub' facilities capable of handling greater volumes and material complexity. The burden of capital investment is increasingly being pushed back down the chain onto waste management companies, who are being asked to process more while managing uncertainty about how that investment will be paid back.

Simpler Recycling was designed to improve feedstock quality through standardised household collections. But cleaner collections at the kerbside don't automatically translate into smoother processing downstream. The reality on the ground is that contamination remains a persistent challenge, driven more by behaviour than infrastructure. Changing how people sort their waste at home requires the kind of sustained public education programmes that haven't been seen since Keep Britain Tidy - the government-backed initiative that used legislation, fines, and mass awareness campaigns to successfully shift public behaviour on littering.

Digital waste tracking, arriving in October, is arguably the change operators are least prepared for. Adoption will be the obstacle, rather than the technology itself. Many businesses in this sector still rely on manual or fragmented recording processes, and the behavioural shift required from teams to move to real-time digital reporting is being significantly underestimated. It's unlikely this problem can be solved in the final quarter of the year.

Where the biggest gaps lie

Ask any operator to identify their primary constraint right now, and processing capacity will likely dominate the answers. The volumes of material that EPR is expected to unlock aren't being matched by investment in the facilities needed to handle them. This is the most urgent infrastructure gap in the sector - the basic ability to process what the regulatory framework is designed to generate.

But why is investment lagging? For the most part, it's not a liquidity problem - the hesitation is driven by risk. The value of recycled plastic is directly linked to oil prices, and when oil is cheap, recycled material struggles to compete economically with virgin feedstock. Operators considering significant capital investment in processing equipment are weighing that cost against a market where the commercial return is genuinely uncertain. The result is paralysis - or, at best, a cautious preference for retrofitting and upgrading existing equipment rather than committing to new capacity.

The make-do-and-mend approach is understandable, but it has limits. Retrofitting buys time, but it won't close the capacity gap. And in a sector where permitting a new site can take years, decisions that are deferred now will not simply become easier to make later - they'll simultaneously become more expensive and more urgent.

The growing skills gap only exacerbates these problems. Larger operators are already investing in recruiting and training the people needed to manage new technologies and more complex processing lines. But smaller operators, who face the same regulatory obligations, are being left behind - creating a growing rift in performance.

The cost of waiting

Most operators in this sector are currently weighing up the same calculation: what does it cost to invest now versus later? The reality is, delaying is rarely a neutral decision - it's a deferred liability that accumulates.

Operators who begin planning and investing now can spread that cost over several years, making informed decisions along the way. Meanwhile, those who wait for absolute certainty before committing are more likely to make rushed investment decisions under compliance pressure, at a higher cost and with less time to embed new systems properly.

The argument for phased, proactive investment is operational as well as financial. New processing equipment, digital systems, and trained employees take time to bed in. Treating infrastructure investment as a compliance backstop - something to do when regulation demands it rather than before - is simply a risk management failure.

An honest conversation

The UK waste sector broadly supports the direction of regulatory travel. EPR, Simpler Recycling, and digital waste tracking are, individually, sensible policies. The problem is the pace and concurrency - and the tendency within the industry to manage the resulting pressure quietly by absorbing it operationally.

What the sector needs now is a more honest collective assessment of where readiness gaps exist and what it will actually take to close them. This conversation requires the government to understand what it's asking of operators, and the industry to be straight about what it can and can't deliver on current trajectories. The regulatory wave is here, but the question of whether the infrastructure can handle it is one we should have been asking louder and earlier.

Marcus Brew is Managing Director at UNTHA UK, which manufactures industrial shredding equipment for the waste, recycling and alternative fuels sectors.

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How will the government and DMOs address the challenges of including glass in DRS while ensuring a level playing field across the UK?

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There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.