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EPR timetable changes: How will this affect forecasting?

Earlier this month The Environment Agency (EA), serving as the regulatory body in England, and the Scottish Environment Protection Agency (SEPA), responsible for regulatory matters in Scotland, jointly issued Regulatory Position Statements (RPS). These statements confirm that no legal enforcement will be taken as long as Extended Producer Responsibility packaging data is submitted by May 31st 2024.

These statements mean that obligated producers no longer have legally enforceable requirements to submit their EPR packaging data by the 1st October 2023 (for January to June 2023 period) and the 1st of April 2024 (for the July to December 2023 time period). However, both datasets will now be required by the 31st of May 2024.

This extension can provide breathing room for businesses to align their resources with the impending changes. Defra, the Department for Environment, Food & Rural Affairs, is yet to provide information regarding EPR fees, which are essential for businesses to prepare for EPR rollout.

A very large number of our members were able to submit their data by the 1st October deadline, and this article will discuss why these data submissions are so vital and why actively engaging with the system benefits your business.

Why is the first EPR data submission important for forecasting?

Submitting your packaging data by the original deadlines holds the key to providing the base data that Defra will use to assess the split of responsibility amongst producers in the EPR system. Defra will use this data as the basis for formulating the EPR illustrative base fees. These illustrative fees will serve as a crucial reference point for producers, enabling you to forecast and budget with greater accuracy. Knowledge of your own data will allow you to factor in the base fees when they are released and give you advance warning of costs.

Effective forecasting is the basis of sound financial planning and strategic decision-making. By submitting your packaging data on time, you contribute to the creation of a reliable foundation for EPR fees. In turn, this empowers your business to anticipate and plan for your EPR obligations, thus ensuring seamless transition to the new regulatory landscape.

Why is the first EPR data submission important for reducing cost under EPR?

With the first EPR payment year deferred until 2025, this gives obligated businesses much needed time to prepare for and reduce their costs under EPR.

Access to a complete dataset on your packaging will enable your business to develop an EPR packaging optimisation strategy. These datasets will provide your business with full visibility of your packaging and what packaging falls under the EPR household waste category, incurring a financial obligation- this will allow your business to identify where packaging, therefore cost, can be reduced.

A detailed understanding of your packaging’s composition and volume empowers you to make informed decisions about material choices and packaging design. This can lead to significant cost savings by reducing excess packaging and streamlining production processes. By analysing the types and quantities of materials used, you can proactively seek alternatives and design changes that reduce both environmental impact and costs.

Supporting the System, Supporting Your Business

The Extended Producer Responsibility system is designed to promote sustainability and environmental best practice in packaging. By submitting your data as early as possible, you demonstrate your commitment to this initiative, providing Defra with much needed information around packaging placed on the market which will inform EPR Producer fees as well as providing your business with information to enable you to make informed decisions on your packaging usage.

The illustrative fees will be of huge help to producers with forecasting, budgeting and packaging optimisation strategies. If you support the system by submitting the first packaging data submission on time, then when illustrative fees are announced, you will have more time for forecasting and preparations.

Your proactive participation will not only benefit the environment but also your bottom line.

A Positive Future

The changes in the EPR timetable offer an opportunity for producers to get ahead. While enforcement action won’t be taken until May 31, 2024, submitting your packaging data as soon as possible, is a proactive step that is of great importance for your business. It lays the foundation for a more predictable and sustainable future, both for your business and the environment.

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