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Essential EPR Glossary: Your Guide to Extended Producer Responsibility Terminology

Navigating the Extended Producer Responsibility for Packaging (pEPR) regulations efficiently requires understanding a range of industry-specific terms and concepts. Whether you’re new to the packaging regulations or need a quick reference, our glossary covers key definitions to help ensure your business remains compliant and well-informed. From “Activity Settings” to “Thresholds,” each entry provides clarity on essential packaging, recycling, and compliance requirements that impact your obligations under UK legislation.

Glossary

2007 Regulations/Shared Responsibility

Refers to the Producer Responsibility Obligations (Packaging Waste) Regulations 2007, the core legislation governing packaging waste in the UK. This refers to the model of shared responsibility, whereby each activity picks up a varying percentage of financial obligation.

Activity Settings

You must choose your activity settings based on your predominant packaging activity. For example, if most of your packaging activity by weight relates to ‘pack/filling’, you would choose this as your activity setting.

Agreed Positions

Interpretations and agreed positions of the Regulators (Environment Agency, Natural Resources Wales (NRW), Northern Ireland Environment Agency (NIEA), and Scottish Environment Protection Agency (SEPA)) relating to extended producer responsibility for packaging (pEPR) compliance.

Base fees

These are the base material costs for Local Authority fees.

Brand identifier

A unique code or name used to identify a specific brand.

Brand Owner

The company that owns the brand of a product.

Brand

The name or mark that identifies a company and/or its products.

Branded vs Unbranded

The Data Regulations define a brand as a brand name, trademark or other distinctive mark. A distinctive mark could be a specific colour or marking (or a combination of the two), that is exclusive or bespoke to the brand owner and is directly associated with the brand, and generally the brand owner has directed the use of that specific colour or mark.

Calculation Year

The calculation year is the calendar year preceding the obligation year. Producers must assess the packaging they handled in the calculation year to determine if they meet the small or large packaging thresholds.

Clarity dashboard

An online tool providing enabling reporting of packaging data for compliance as well as providing helpful resources.

Commonly binned

Packaging items that commonly end up in public bins.

Compliance Scheme

A business that helps obligated producers comply with their packaging waste obligations (e.g. Clarity Environmental) by working together to collate, verify and submit packaging data to the relevant governing body.

Compliance Year

Same as ‘obligation year’.

Data Services

Usually, services provided by compliance schemes to help producers with data collection, verification, and reporting for compliance, such as Dynamic Data by Clarity.

Drinks container

Single use drinks containers which are reported separately from other packaging, when they meet the following criteria:

EPR Fees

Fees related to the EPR scheme cover the full net cost of packaging waste. Your PRN costs will cover both Household, Non-Household and Local Authority costs.

Note: Local Authority costs are only applicable if you’d submitted packaging data under the Household category. Local Authority payments are paid directly to the Scheme Administrator.

Enterprise Resource Planning (ERP)

Business management software that may contain packaging data.

ePRNs

Packaging Export Recovery Notes. As above, but export rather than re-processed in the UK.

Established in the UK

A business with its registered office, head office or principal place of business outside the UK, is established in the UK if it has a branch or postal address in the UK. This could be a PO box, office, warehouse, or domestic premises (if they are used for the purpose of the business).

Filled vs Unfilled

A description of packaging containing product (filled) or empty (unfilled).

Group

A collection of companies under common ownership.

Household & Non-household packaging

Household packaging is typically discarded by consumers at home (e.g., bottles, food containers). Non-household packaging is used in commercial or industrial settings, such as transport or business packaging.

Importer

The first UK established company to own packaging/product either brought in from outside the UK or previously owned by a company outside the UK. The invoice trail may be relevant to determine ownership.

LA (Local Authority)

A local government body, usually councils, to whom the waste management fee will be allocated.

Large producer

A business with a turnover of £2m+ and 50t+ packaging supplied or imported p/a. Both turnover and packaging supplied or imported thresholds must be satisfied to be considered a large producer.

Latest audited accounts

The most recent officially audited financial records of a company.

Modulated Categories

Categories of packaging subject to modulated fees.

Modulated Fees

LA Fees adjusted based on the recyclability of packaging. These will be introduced in year 2 of EPR.

Nature of business

The type of business activity a company undertakes.

Obligation

The legal responsibility of producers to contribute to the recovery and recycling of packaging waste.

Obligation Year

The obligation year is the calendar year in which a person has the obligations of a small or large producer. For example, a person who met the large producer turnover threshold and who also met the large producer packaging handled threshold in 2022 (the calculation year) will be subject to a large producer obligation in 2023 (the obligation year). This means in 2023 that person must collect and report packaging data.

Org ID

A unique identifier for an organisation generated by the RPD. See ‘RPD Portal (Report Packaging Data)’ definition.

Pack/filler

The company that packs or fills packaging in the UK.

Packaging Activity

The actions a business performs regarding packaging (e.g. pack/filling, supplying as empty, importing).

Packaging Grade (materials)

The type of material the packaging is made from (e.g., plastic, paper, glass, aluminium).

Packaging Handled vs Packaging Supplied

Under EPR, packaging liable for reporting is described as ‘packaging supplied’, whereas under the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 it was described as ‘packaging handled’, which included the nation of sale.

Packaging Type

The description of packaging (e.g., bottles, cartons, trays).

Predominant Weight

When referring to multi-material packaging, this means the main material by weight. When referring to determining your main packaging activity, it is the main packaging material supplied by weight within a packaging activity.

Primary Packaging

Primary packaging is what’s used to contain a single ‘sales unit’ to sell to customers. For a sales unit that’s made up of lots of items, such as a multipack, the primary packaging includes all of the packaging on the items.

PRNs (Packaging Recovery Notes)

Certificates proving that packaging waste has been recycled. These are claimed by reprocessors and purchased by schemes and obligated producers to meet recycling obligations.

Public Institution

An organisation funded and operated by the government, such as schools, hospitals, or government offices, that serves the public. Certain exemptions or considerations apply for public institutions, so it’s best to work with your compliance scheme (e.g. Clarity) if you have questions around this.

RAM (Recyclability Assessment Methodology)

The Recyclability Assessment Methodology is a framework for assessing packaging recyclability in the UK.

Recyclability

The potential for packaging materials to be processed and reused in the production of new items, reducing waste and conserving resources.

Reusable vs Reused

“Reusable” refers to packaging designed for multiple uses. “Reused” means packaging used one or more times, even if not originally designed for that purpose.

RPD Portal (Report Packaging Data)

All obligated businesses must create an account on the Government’s Report Packaging Data (RPD) service before being able to complete a data submission.

Secondary Packaging

Secondary packaging is for grouping several ‘sales units’ for selling or transport purposes. Organisations may also use secondary packaging to display goods in shops.

Self-Managed Waste

Self-managed waste refers to packaging waste that your business collects and sends for recycling. There are two types of self-managed packaging waste to be reported: Self-managed organisation waste, and self-managed consumer waste.

Shipment

Shipment packaging is any packaging added to primary packaging for goods sold online or by mail order and delivered directly to the purchaser or to a shop or collection point. Shipment packaging can include cardboard boxes, bubble wrap and mail bags.

Small producer

A business with a turnover of £1m+ and 25t+ packaging supplied or imported p/a, that doesn’t meet the large producer threshold. Both turnover and packaging supplied or imported thresholds must be satisfied to be considered a small producer.

Street binned

Same as ‘commonly binned’.

Submission deadline

The deadline for submitting packaging data for a given time period. We advise you to stay up to date with communications from your compliance scheme as dates may differ from final government deadlines.

Submission period

The period covered by a data submission (e.g., H1 Jan-Jun, H2 Jul-Dec).

Submissions

The act of submitting packaging data.

Subsidiary

A company controlled by a parent company.

Tertiary

Tertiary or transit packaging is used to group secondary packaging units together to protect them while being transported or handled through the supply chain.

Threshold

The turnover and packaging supplied or imported level that triggers packaging waste obligations. Small producer thresholds are £1m+ turnover and 25t+ packaging supplied or imported p/a, whereas large producer thresholds are £2m+ turnover and 50t+ packaging supplied or imported p/a.

Turnover

The annual revenue of a business.

UK Brand Owner

The brand owner defined as established in the UK.

UK Presence

Same as ‘established in the UK’.

EPR Guidance

Do you or your business require further information about EPR? Reach out to our team of experts to book a free EPR consultation to review your business needs.

Alternatively, if you are a Comply with Clarity member and require further information on the revised timetable and your responsibilities, please get in touch utilising the form below, your compliance manager will respond to any of your questions.