OPINION: ‘RPD reporting system is hugely adding to pEPR stress’

OPINION: It’s certainly been a hectic month for EPR. Whilst producers are generally getting in the flow of six-monthly reporting, for many companies, obtaining supplier data is still a significant challenge. On top of that is the dreadful “Report packaging data” (RPD) reporting system which adds hugely to the stress of meeting the deadline, especially when a problem occurs that can sometimes take weeks to get resolved by the Defra digital team.

For reprocessors and exporters, it is the dawn of a new era. The start of September was supposed to see the opening of the new digital registration and accreditation system. However, despite the £84 million cost of EPR digital development, the new system is still some weeks off and operators were presented with a stop-gap process that has limitations. For instance, once you submit an application, you can’t then see what you’ve submitted. And for overseas sites, applicants in England have to rename all the site licence files for upload onto a file sharing site which will be a challenge for the Environment Agency (EA) to manage.

However, the biggest change in the application process is the need for all reprocessors and exporters of packaging waste to have to submit a registration application and then if they wish to issue PRNs next year, to submit a separate accreditation application. These require separate, new format sampling and inspection plans with many more questions than had to be answered under the old regime. This means that the regulators are likely to have received over 500 applications and over 1,000 sampling and inspection plans to assess by 01 January, a mammoth task. For the applicants though, the new agency fee system has seen some huge increases, mainly for exporters who now have to pay a fee for each overseas site they are registering. One exporter, for instance, is having to pay over £30,000 in application fees compared to £2,616 in 2024.

We don’t yet know how the reporting systems for packaging data and PRN information will work next year, but for both the regulators and industry, the next three months will be extremely challenging, not helped by the limitations and complexity of the digital system on which EPR depends.