What is EPR for Packaging?
Producer responsibility for businesses that supply or import packaging in the UK is changing with the phased implementation of Extended Producer Responsibility (EPR) from 2023. EPR is a policy tool which requires producers to be responsible for the full net cost of managing the packaging they place on the UK market at the end of its life. The UK Government first announced their intention to introduce EPR for packaging in the Resources and Waste Strategy published in 2018 and have since published several consultations.
EPR is a reform of the existing Packaging Waste Regulations (PWR) which is being phased in from 2023. Data reporting under EPR will run alongside the PWR’s for 2023 and 2024 with requirements under both sets of legislation. From 2025, EPR will replace the PWR, and obligated producers will be required to both reporting and finance EPR obligations.
Who is obligated under EPR?
A business will have an obligation under EPR if it’s annual turnover exceeds £1 million, and it supplies and/or imports over 25 tonnes of packaging in a calendar year.
There are two key thresholds which determine whether an organisation responsible for packaging will be obligated with reporting only as a Small Producer or reporting and financing obligations as a Large Producer.
- Large Producers (LP) exceed both £2m annual turnover and more than 50 tonnes of packaging supplied/imported in a calendar year. LP’s will be required to report biannually from 2023 and finance EPR obligations via PRN/PERNs and the LA Waste Management Fee from 2025.
- Small Producers (SP) have either an annual turnover between £1m & £2m, and more than 25 tonnes of packaging supplied/imported in a calendar year OR an annual turnover over £1m and between 25 and 50 tonnes of packaging supplied/imported in a calendar year. SP’s have annual data collation obligations from 2023, with annual packaging data for 2024 required for submission early 2025.
If you meet either of these thresholds our team can help you understand what EPR means for your business - contact us today.
Some LP's and SP's may be required to submit nation data annually in addition to the standard EPR data reporting. Nation data is information about which country in the UK your packaging has been sold, hired, loaned, gifted or discarded in.
Our team is helping producers report for EPR, for more information and to understand exactly how we can help you...
Key points to be aware of:
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- The new Small Producer threshold will see more packaging producers reporting data.
- Under EPR there will be more complex data requirements, including biannual submissions for Large Producers.
- Separate reporting requirements to report packaging supplied by nation for certain producer types.
- A new Local Authority (LA) Waste Management Fee will be introduced from 2025, in addition to PRN/PERN costs.
- For Large Producers the next EPR reporting period is 2024 period 1 covering packaging supplied or imported from January to June 2024. Submissions for this period will be accepted from July 2024.
- For Small Producers the next EPR data reporting period is January to December 2024. Submissions for this period will be accepted from January 2025.
- A modulated fee structure will be introduced offering financial incentive to encourage sustainable packaging design to reduce EPR costs. Those difficult-to-recycle or unrecyclable packaging materials will attract higher fees.
- Mandatory labelling will be in place from 2027, and all packaging will need to display a binary 'recycle' or 'do not recycle' label.
FAQ's
Businesses obligated under EPR should begin to collate data under EPR rules from 1st January 2023.
For Large Producers (LPs) the first EPR reporting period is January to June 2023. Submissions for period 1 will be accepted from July and must be with the regulator by 1st October 2023. The second reporting period for LPs is July to December 2023. Submissions for period 2 will be accepted from January 2024 and must be with the regulator by 1st April 2024. These data collection and reporting timeframes will continue year-on-year for LPs, with financing of these obligations introduced from 2025 based on previous year data supplied.
For Small Producers (SPs) the EPR data collection period is annual, the first being January to December 2023. SPs are not required to submit their annual data until the 2024 collection period, where submissions will be accepted from January 2025 and must be with the regulator by 1st April 2025. Going forward the data collection and reporting timeframes will continue year-on-year for SPs.
All packaging handled and/or supplied in the UK under the below packaging activities contributes to reaching the EPR threshold.
EPR Packaging Activities include:
- Brand Owner – supplying packaged goods to the UK market under your own brand.
- Packer/Filler – placing goods into packaging that’s unbranded when it’s supplied.
- Importer – importing products in packaging.
- Online Marketplace (OMP) – operating an online marketplace set up to allow non-UK businesses to sell their goods in the UK.
- Service Provider – hiring or loaning out reusable packaging.
- Distributor – importing/manufacturing and supplying empty packaging.
- Seller - supplying filled packaging to consumers or organisations in the UK who are the end-user of the packaging (i.e. they discard/recycle/reuse the packaging).
For turnover, the requirement is the figure registered on a business’s latest filed UK accounts.
If you’re unsure on this, please contact our team to help identify if your business reaches the thresholds for EPR.
Small Producers (SPs) have either an annual turnover between £1m & £2m, and more than 25 tonnes of packaging handled in a calendar year OR an annual turnover over £1m and between 25 and 50 tonnes of packaging handled or supplied in a calendar year.
Large Producers (LPs) exceed both £2m annual turnover and more than 50 tonnes of packaging handled or supplied in a calendar year.
SPs have annual reporting only obligations, and packaging data for 2024 will be required for submission early 2025. LPs will be required to report biannually from 2023 and finance EPR obligations via PRN/PERNs and the LA Waste Management Fee from 2025.
Some LPs and SPs may also need to submit nation data annually. This is an additional requirement for information on where packaging has been sold, hired, loaned, gifted, or discarded.
An organisation will need to submit nation data if it sells filled packaging to a consumer who is the end user of the packaging. A consumer is an individual acting for purposes which are outside that individual's trade, business, craft or profession. Nation data is to be collated and reported annually.
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With EPR reporting requirements for many this year, the new regulation may be a daunting prospect. With over two decades experience in producer compliance our team have the knowledge and skills to support your EPR compliance.
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