2024 Packaging and Waste Legislation Updates Summary

Legislation Tracker 2024 Packaging and Waste What? When? Next Steps Confirmed (Y/N) Waste Segregation Wales Apr 24 Ensure that waste streams are segregated for recycling and that waste management contractors are set up to collect these separate streams from restaurants. Y Already underway Make segregated bins available in the front of house to customers. We will not require staff to sort waste if customers do not correctly sort it at the point of disposal. Providing the bins and means of segregation would be deemed as providing reasonable steps to comply. Materials will be food, paper, glass, metal, plastic and cartons. Further detail here Simpler Recycling Mar 25 Reforms are planned for recycling collections in England for businesses for 2025. The English scheme allows for all Dry Recyclables to be collected together so will make the waste segregation easier than has been implemented in Wales. (N.B. Exemption still needs to be passed by DEFRA and does depend on how a business waste management provider chooses to collect). DMR and food waste to be must collected from March 2025. Waste bins needed front of house. Y confirmed as unlikely to change by DEFRA. DMR and food waste to be collected from March 2025. Extended Producer Responsibility Oct 25 EPR is due to start in October 2025, with annual disposal costs payable by producers from financial year 2025 to 2026. Drink containers made of PET plastic, aluminium, and steel will be excluded from disposal cost fees and labelling obligations under EPR. Large organisations need to submit data every 6 months Y going ahead, with invoices October 2025. (data collection already in place) Projected costs are roughly x7-8 what we are currently paying for packaging compliance. Illustrative base fees have been released Aug 2024, the next iteration is in September and then payments to Local Authorities they will be confirmed November. Base fees will be coming April 2025 once they have all the data. Modulated fees are expected to come in Y2 of the regulation and DEFRA is working on a recyclability Assessment Methodology (RAM) which feeds into this. Deposit Return Scheme Oct 27 DRS places a deposit on drinks containers made of PET, steel, and aluminium. This will be a 10-20p deposit on every drink sold. Each retailer will need to provide a return point for customers to collect their deposit. The retailer then returns the container to the scheme administrator who refunds the deposit to the retailer. The position on glass containers is TBD. (Currently Wales glass is included). Y regulations due to be in place in Jan/Feb 2025. Still going live Oct 2027 All 4 UK nations Operators only be required to take back products we have sold. (New collection system will be in place by Privately Run DMO) Where drinks are consumed on the premises, drinks can only be bought from a registered producer and the company must pay for the deposits on each drink.

Legislation Tracker 2024 Packaging and Waste What? When? Next Steps Confirmed (Y/N) Mandatory Cup Take Back 2025 Will require all BKUK supply consumers with beverages in fibre-based composite cups filled at the point of sale, to provide a visible bin at the premises for the collection of recyclable cups. DEFRA yet to confirm details on process and/or associated charges (Not confirmed but when it is you will need a separate cup collection on site and be prepared to report your cups placed on market) N Not confirmed by DEFRA Further detail here PROPOSED Scottish and Northern Irish Cup Levy 2025 Scotland: A minimum of 0.25 charge on any single-use beverage cup (inc. biodegradable and plant based) to be implemented by the end of 2025 as part of Circular Economy Bill. The Scottish government started a consultation on this in August 2024. This is set to be completed November 2024 Further detail here N but we await results of consultation (some media outlets reporting it will go live) NI: There had been discussions around a similar levy in Northern Ireland (one already exists in the ROI). However there haven t been any movements on this since 2023. Mandatory Food Waste Reporting NA The UK Government has revealed it will be sticking with a voluntary approach to food waste reporting, though this could be looked at further by the Minister as there is currently a team focused on the food value chain. N Environmental Protection (Single- use Plastic Products) (Wales) Bill 2024 Ban on polystyrene lids for cups and food containers. BKUK currently compliant as the legislation doesn t cover our products, but it will do in Spring 2026 N- phase 2 is due in 2026 but there haven't yet been announcements Further detail here

Legislation Tracker 2024 Packaging and Waste What? When? Next Steps Confirmed (Y/N) UK REACH on PFA (Poly- and perfluoroalkyl substances) October 2027 (unless we were already required to EU) PFAS are a group of over 10,000 industrial chemicals, used in a wide array of products and processes, that now pollute air, soil and water worldwide. Mounting evidence of their adverse environmental and human health impacts has led to increased international scrutiny and regulatory action. Need to ensure that products are PFAS free. N but we need to confirm Companies that manufacture or import over 1 tonne have to comply by managing the risks, collecting, and submitting data on these substances. The EU have their own legislation (EU REACH) Further detail here and UK REACH: UK REACH Explained (hse.gov.uk) UK Emissions Trading Scheme 2028 Waste incineration will be included in UK ETS from 2028. Costs will apply to the fossil portion of waste so you will be taxed on anything incinerated. No exemptions for any kind of waste N updates expected 2026 (Note: Landfill tax increase is due in April 25 by +22%. This will also affect gate fees for Transfer Stations and EFW. Landfill bans (e.g. on biodegradable waste) are also expected. Further detail here Digital Waste Tracking April 2025 Proposal to have digital tracking of where and how waste is created, who handles it and the destination. This will replace outdated systems like electronic duty of care. Y - confirmed, no visibility of responsibilities

Legislation Tracker 2024 - Planet What? When? Next Steps Confirmed (Y/N) Biodiversity Net-Gain Feb 24 BNG makes sure development has a measurably positive impact ( net gain ) on biodiversity, compared to what was there before development. Y already underway Developers must deliver a BNG of 10%. This means a development will result in more or better quality, natural habitat than there was before development. Energy Savings Opportunity Scheme (ESOS) Dec 24 Phase 3 submission deadline was 6 August 2024. Y in play From Phase 3 onwards, ESOS includes additional compliance stages - ESOS action plans and ESOS annual progress updates. Action plans must be signed off by a board level director and submitted via the compliance notification system, with the first deadline 5 December 2024. TCFD (Taskforce for Climate related Financial Disclosures) NA Requirements on large private companies to incorporate TCFD aligned climate disclosures in their annual reports. This includes - UK companies with over 500 employees and turnover of over 500m - UK companies currently required to product non-financial information statements N- not a legal requirement for BK Further detail here TNFD (Taskforce for Nature related Financial Disclosures ) NA Not yet mandatory, but could be in the future as it relates to other disclosures in Europe like CSRD. It covers nature, biodiversity and degradation of ecosystems. It focusses on nature risks and business opportunities e.g. ecosystem services N- not mandatory UK Carbon Border Adjustment Mechanism (CBAM) Jan 27 Impacts suppliers rather than operators. On imports of certain carbon intensive imported goods from the following sectors: aluminium; cement; ceramics; fertilisers; glass; hydrogen; and iron and steel. N waiting for results from 2024 consultation

Legislation Tracker 2024 - Planet What? When? Next Steps Confirmed (Y/N) Forest Risk Commodities ~Jul 25 New requirements and timetable for retailers to demonstrate products are not sourced from deforested areas. There are 4 in-scope commodities: soy; palm oil; cocoa; and beef (dairy is excluded) includes soy in feed Y to come Jul 2025, confirmed to go ahead by Labour Goods Not for Resale are NOT in scope e.g. soap, detergents. Soy in feed will be the most difficult commodity to map. This legislation is similar to EU deforestation regulation. EU Deforestation Regulation 31 Dec 24 Impacts any cocoa, coffee, palm, soy (inc. Soy used for beeffeed), wood, and cattle imported from and exported to the EU market. We need to ensure the first company to place these commodities on the EU market is conducting due diligence and we need to keep records of geolocation and proof of deforestation free status of these commodities. Y need to finalise compliance by Dec 2024 31st May 2024 UK s Sustainability Disclosure Requirements (SDR) This is a new reporting framework for financial companies to improve transparency and accountability in sustainability reporting. Likely to apply to investors rather than operators directly. N only applies to financial organisations and is not confirmed by new gov Green Claims Code 2021 Designed by the Competition and Markets authority, this checklist helps business to ensure they do not get called up for greenwashing. Y in play UK Carbon Border Adjustment Mechanism (CBAM) Jan 27 This will affect our suppliers. On imports of certain carbon intensive imported goods from the following sectors: aluminium; cement; ceramics; fertilisers; glass; hydrogen; and iron and steel. N waiting for results from 2024 consultation The Building Regulations 2024 Apr 24 Updates to the building regulations include Renewable Energy Integration encouraging new buildings to use renewables inc. solar, heat pumps. Updated U-values looking into how well the building retains heat. Y in play

Legislation Tracker 2024 - Nutrition What? When? Next Steps Confirmed (Y/N) Advertising Restrictions HFSS Oct 25 9pm watershed on TV and a ban of paid-for above and below the line and online advertising for HFSS food No Labour have announced they will legislate against advertising junk food but haven't confirmed whether this legislation is going ahead The labour government announced that they will legislate to restrict advertising of junk food to children during the Kings speech on 17th July 2024. However, the legislation have not been confirmed. Further detail here Advertising Restrictions HFSS Oct 25 Volume promotions of certain high-fat, sugar products ban comes into force. No Labour have announced they will legislate against advertising junk food but have not confirmed whether this legislation is going ahead Volume promotions of certain high-fat, sugar products ban comes into force. The HFSS rules aim to restrict the promotion of less healthy food and drink products as part of the government s pledge to reduce obesity and improvehealth. In England, the regulations cover the placement of promotions in store, multibuy promotional offers such as BOGOF (buy one get one free), and advertising online and on TV before 9pm. Further detail here Ban on energy drinks to under16s 2025 Any energy drink containing more than 150mg of caffeine per litre would not be available to anyone under the age of 16. The policy is expected to be enforced by Trading Standards. Yes Labour will set out the legal framework and technical guidance for the new legislation PROPOSED Welsh Meal Deal Restrictions 2025 Meal deals with a high fat, sugar or salt content will be restricted in Wales under plans to tackle obesity and diabetes. Price drops and multi-buy offers on unhealthy foods will be banned in the Welsh government's proposals.

Legislation Tracker 2024 - People What? When? Next Steps PROPOSED Human Rights Due Diligence - One to watch Likely to include a duty to prevent and mitigate human rights and environmental harms so far as is reasonably practical. This would be within our own operations, products and services, those of our subsidiaries and throughout our value chains. EU legislation has been adopted as of Apr 24, and likely UK law will follow PROPOSED Commercial Organisations and Public Authorities Duty (Human Rights and Environment) Bill - One to watch Currently a private members bill: to undertake human rights and environmental due diligence to identify, address, prevent, mitigate and remedy harms in their operations and value chains. hold companies accountable for a failure to prevent abuses through liability provisions. help to level the playing field between businesses, bringing them all up to the same standard of practice and providing clarity and certainty on legal obligations. enable victims of abuses, including modern slavery, to access justice through the courts of the home country of the lead company in a supply chain.

Legislation Tracker 2024 - EU Regulation to Watch Out For What? When? Next Steps Confirmed (Y/N) Industrial and Livestock Rearing Emissions Directive (IED 2.0) - replacing previous document from 2010 4th Aug 24 Annual environmental inspections industrial pork and poultry farms, organic is excluded. Member states report emissions on behalf of farmers. This information will enable member states to draw up 'transition plans' for their farms with these plans coming into effect 2030/32 N This may impact our suppliers, but we firstly need to determine the size of all farms Scope: Pig farms with 350 Livestock Units approx. 1,100 pigs, 700 sows (this threshold has lowered from previous scope) Poultry farms with 280 Livestock units approx. 40k chickens for meat (unchanged from previous scope) Egg producing farms with 21,400 laying hens (this threshold has lowered) Penalties include 3% a companies annual turnover & citizens claiming compensation for 'illegal pollution' We can use the legislation to gather stronger emissions data via new Industrial Emissions Portal Regulation (IEPR) Corporate Sustainability Reporting Directive (CSRD) 1st Jan 2024 (companies already subject to NFRD) Non-EU companies with a net turnover of 150 million in the EU, and with at least one subsidiary or branch in the union will be subject to this this would be for RBI EU companies subject to legislation report in 2025 is they meet 2/3 of: 40 million net turnover, 20 million total assets, 250 employees Have an EU branch that generates a net turnover exceeding 40 million N This will be for our suppliers and RBI not BKUK 2025 (large companies not subject to NFRD) 2026 (med to small companies) CSRD reporting for UK and other non-EU companies | Normative