With the first EPR data submission now passed (1st October 2023), the phased implementation of Packaging Extended Producer Responsibility (EPR) in the UK is in full swing. Obligated producers should be preparing for the two EPR data submission in April and October as well as the final submission under the Shared Responsibility system also due in April.
To assist businesses in preparing for EPR and the final data submission of the 2007 Packaging Waste Regulations (Shared Responsibility), Clarity has put together the following guide on what you need to do in order to comply with all packaging waste regulations for 2024.
✓ Collect Your Data
With 3 data submissions in 2024, obligated businesses are mandated to collect detailed EPR packaging data from 1st March 2023.
Under Shared Responsibility, obligated businesses will already be collecting some packaging data ahead of the final submission in April 2024.
There is some cross over of data needed for the Shared submission and EPR however, the information needed for the EPR submission(s) requires additional granularity.
Shared Responsibility Submission
You must collect packaging data on:
- Material type
- Material weights
- Packaging activity/producer type
You must submit your Shared Responsibility report by 1st April 2024, or in February if you are using a compliance scheme.
Extended Producer Responsibility Submission(s)
- Packaging material type
- Packaging material weight
- How your packaging was supplied to the market
- Packaging type
- Waste type
✓ Prepare Your Packaging
In 2025, Defra will require the first submission in the modulated fee format where hard-to-recycle packaging materials will incur a higher waste management fee than easy-to-recycle materials which will have a reduced fee under EPR.
Despite minimal information on modulated fees, it is encouraged that you begin reviewing and optimising your packaging format now by introducing easy-to-recycle materials into your packaging as well as reducing your packaging overall.
Although the initial focus of eco-modulation is on recyclability, Defra will consider broader environmental implications of packaging materials in later EPR revisions. These modulations encompass Local Authority collection and sorting costs, featuring bonuses for some materials and malus for others. Begin preparing for these changes now to avoid higher fees further down the line.
As well as modulated fees being introduced in 2025/26, there will also be an introduction of mandatory recycling labelling. Begin preparing for these changes now in order to avoid added costs further down the line.
✓ Refine and Submit Your Data
Once you have collected and recorded your packaging data in the desired EPR format as well as having prepared a separate submission under Shared Responsibility, you must submit these data reports to Defra or to your compliance scheme for verification.
The final Shared Responsibility submission must include:
-
-
Your main packaging activity
This is how you put the packaging on the market and what your role was when you put the packaging on the UK market. This is split up into different activities, these are:
- sell packaged goods
- Pack fill packaged good
- Converter of packaging
- Raw material manufacturing
-
Any secondary packaging activities
- Materials imported
- Materials exported
- Packaging around imports that you remove as an end user
-
Packaging Material type and weight (in tonnes)
This is recorded in the categories of:
- Aluminium
- Glass
- Paper or cardboard
- Plastic
- Steel
- Wood
- ‘Other’ e.g., rubber, cork etc
-
How you worked out how much packaging you handled in the previous year
-
You must submit your Shared Responsibility report by 1st April 2024, or in February if you are using a compliance scheme. This data submission will be for the period of Jan-Dec 2023.
The Extended Producer Responsibility for packaging data submissions must include:
-
Packaging activity
This is how you put the packaging on the market and what your role was when you put the packaging on the UK market. This is split up into different activities, these are:
- supplied under your brand
- packed or filled as unbranded
- imported
- supplied as empty packaging to a producer who sits below threshold
- hired or loaned
- supplied through an online marketplace that you own
-
Packaging material and weight
This is recorded in the categories of:
- Aluminium
- Glass
- Paper or cardboard
- Plastic
- Steel
- Wood
- ‘Other’ e.g., rubber, cork etc
- Fibre-based composite (new for EPR)
-
Packaging type
This is recorded in the categories of:
- Primary
- Secondary
- Shipment
- Tertiary
-
Waste type
This is recorded in the categories of:
- Household waste
- Non-household waste
- ‘On the go’ drinks containers
- Street bin waste
- Reusable packaging
- Self-managed waste
You must submit your Extended Producer Responsibility submissions by 1st April 2024 for your 2023 H2 data for the time period of Jul-Dec 2023 (February if you are using a compliance scheme). The third submission of 2024 will take place 1st October 2024 for your 2024 H1 data for the time period of Jan-Jun 2024 (August if you are using a compliance scheme).
Some businesses are required to collect nation of sale data, this data will be submitted in July 2024 or the time period of Jan-Dec 2023.
✓ Purchase Required PRNs
To ensure you are compliant with Shared Responsibility and Extended Producer Responsibility in 2024, you must continue to purchase packaging (export) recovery notes (P(E)RNs). Many businesses will have already been purchasing recycling evidence to comply with the Shared Responsibility Regulations; under Extended Producer Responsibility, the purchasing of P(E)RNs remains the mechanism through which obligated businesses comply with their recycling obligations. Under the new system, obligated businesses will continue to purchase P(E)RNs as they do now however, there will be an additional Local Authority waste management fee to cover the full net cost of collection, treatment and sorting of packaging waste.
PRNs subsidise the cost of actual recycling in the UK whereas EPR will cover the full net cost of the collection, treatment and sorting costs of packaging waste.
✓ Comply
Once you have registered with the Scheme Administrator (SA), registered with the relevant environmental regulator, submitted all three packaging data reports to your compliance scheme and you have purchased the appropriate amount of recycling evidence, you have met the legal requirements for EPR and the 2007 Packaging Waste Regulations for 2024!
Your local authority waste management fee and SA administrative payments will begin from 2025.
How Can Clarity Help?
In 2024, some organisations will have 8 separate compliance reports: Plastic Packaging Tax, Shared Responsibility submission, The Plastic Pact and Extended Producer Responsibility. As the regulatory landscape becomes increasingly complex, with increased scrutiny from the regulators such as the EA and HMRC, it is more important than ever to achieve accuracy in your packaging data.
With our team of packaging compliance and data experts, Clarity can help your business stay compliant, save time and achieve peace of mind. If you would like to find out more about how our EPR solutions can work for your business please reach out to us on info@clarity.eu.com or book an EPR consultation to discuss your needs.