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EPR for packaging: How to prepare

Extended Producer Responsibility (EPR) for packaging is a policy instrument that places financial responsibility for managing packaging waste onto packaging producers. It is the idea that those placing packaging on the UK market should be responsible for the full net cost of the collection, sorting and treatment of packaging waste.

Producers obligated under EPR have been mandated to collect detailed packaging data since the 1st March 2023 as part of the first phase of EPR implementation. This data will inform packaging producers first Local Authority Waste Management fee which will be paid to the scheme administrator from June 2024.

To assist businesses in preparing for EPR, Clarity has put together the following guide on what you need to do in order to comply with UK EPR, and how to prepare for phase two of the new legislation.

1. Determine Your Obligations:

Identify whether your business falls under the scope of the EPR regulations. This depends on factors such as your tonnage of packaging placed onto UK markets and your annual turnover. To find out if you’re obligated, use Clarity’s free online obligation checker tool here.

2. Understand the EPR Regulations:

Familiarise yourself with the EPR regulations and ensure you are aware of any ongoing policy reform. These regulations will outline the requirements, targets, and timelines for packaging compliance. To stay on top of all policy and industry updates subscribe to our monthly newsletter Clearviewlite, offering expert guidance, crucial policy updates, and the latest industry news.

3. Record Detailed Packaging Data:

Obligated businesses are mandated to collect detailed packaging data from 1st March 2023. Under Producer Responsibility, obligated businesses will have already been collecting some packaging data ahead of the final submission under the current system in April 2023 however, the information needed for the first EPR submission by 1st October requires data under the new single point of compliance format.

Although the deadline to submit your packaging data to the scheme administrator is by 1st October, your compliance scheme will likely require this information earlier.

You must collect packaging data on:

  • Packaging material type
  • Packaging material weight
  • How your packaging was supplied to the market
  • Packaging type
  • Waste type
  • Some businesses are required to collect nation of sale data, this data will be submitted to your compliance scheme in August 2024 for the time period of January-December 2023.

4. Purchase the relevant volume of recycling evidence:

All packaging producers obligated under the current system will have already been purchasing Packaging (Export) Recovery Notes (P(E)RNs) as part of their compliance with the 2007 Packaging Waste Regulations. Businesses obligated under Extended Producer Responsibility will continue to purchase recycling evidence in order to comply. Due to the single point of compliance element of EPR there will be businesses no longer in-scope of packaging waste regulations who therefore will not need to continue to purchase PRNs. Check if you’re obligated here.

5. Implement Packaging Waste Reduction Measures:

The ultimate aim of Extended Producer Responsibility for packaging is to minimise the environmental impact of packaging and improve resource efficiency. These aims are achieved through financially incentivising packaging producers using a modulated fee framework, where packaging materials with a higher environmental impact will incur a higher fee under EPR thereby reducing the fees for packaging materials with a lower environmental impact. The modulated fee system will begin in 2025, with the first billing under the modulated system in 2026. The modulations will be based on an assessment of recyclability however, going forward Defra may consider other environmental factors such as carbon impact in how fees are modulated.

To reduce your fees under EPR and reduce your environmental impact, it is important to begin reviewing your packaging format to optimise your packaging design to reduce your packaging and use easier to recycle materials and consider the wider environmental impact of your packaging.

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Need support with EPR?

If you have any questions on EPR or would like to discuss your obligation and compliance to the EPR system, please contact us and one of our EPR specialists will contact you same day.