New packaging EPR producer requirements have begun
– here’s what you need to know
What is packaging EPR?
Packaging Extended Producer Responsibility (EPR) is a policy tool that came into force on 1 January 2023 to make producers much more responsible for the packaging they place on the market.
The purpose is to incentivise the use of less and more easily recyclable or reusable packaging materials, ensure that as much packaging material as possible is recycled and that adequate funding is raised to cover the cost of collecting and recycling packaging material when it becomes waste.
Who is impacted?
Packaging EPR applies to all UK organisations that handle and supply packaging to consumers and to businesses.
Businesses that meet certain threshold criteria set by the government will have to register, pay administration fees, and complete significant data collection and reporting actions.
Data reporting obligations begin in 2023 but financial obligations under EPR won’t start until 2025 – instead the existing data and PRN obligations under the 2007 packaging waste regulations will continue in 2024 for those that meet the previous threshold of 50 tonnes of packaging handled and £2m turnover.
Businesses may be required to act under packaging EPR if the following applies to them:
- They are an individual business, subsidiary, or group, but not a charity
- And have an annual turnover of £1million or more
- And are responsible for over 25 tonnes of packaging per calendar year
- And they fulfil any of the seven packaging activities listed by the government
If a business meets the main EPR threshold, the next step is to work out whether it is classed as a small or large organisation under the EPR regulations. This will determine any reporting and financial obligations due, and the deadline for the actions that must be taken.
It is important to note that packaging EPR uses a single point of compliance. In most cases, this will rest with the brand owner or importer of the packaging. Whomever the point of compliance sits with, they alone need to fulfil any reporting and financial obligations linked to their packaging.
One exception is a reporting requirement to identify which UK nation the packaging is sold into. This may sit with a different organisation that is selling packaging to consumers.
Mandatory labelling requirements will also be enforced from 2026 to help consumers to identify whether packaging is recyclable or not.
When is it happening?
Phasing-in of packaging EPR began on 1 January 2023 and is expected to be fully implemented by 2027. Watch our explainer videos here to run through the key implementation dates you need to know.
What do you need to do?
Getting to grips with packaging EPR can be complex no matter the size of your organisation, but Ecosurety is here to help you with four key steps you need to focus on:
- Prepare to understand how your organisation is impacted and the required actions to take.
- Collect all the required data about your packaging.
- Comply by registering, submitting data, and paying financial obligations on time.
- Improve by reducing the environmental impact of your packaging and your EPR liabilities.