Regulatory Agencies Extend Deadline for EPR Packaging Data Reporting

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

These statements mean that obligated producers no longer have legal requirements to submit their Extended Producer Responsibility for Packaging, packaging data by the 1st of 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. 

The key messages in these RPS announcements are that no legal enforcements will be initiated against businesses registered in England and Scotland, as long as they adhere to the extended deadline for submitting the packaging data required to comply with the UKs EPR for packaging legislation. The new deadline is 31st May 2024. This extension has been implemented to accommodate businesses facing challenges in meeting the initial reporting deadlines and to ease the compliance process. 

For clarity, this now means that the current reporting dates are no longer legally binding for the 2023 H1 and H2 data. Both datasets, for the period of January to June 2023 (which was due on 1st of October 2023) and for the period of July to December 2023 (which was due on 1st April 2024) are now both due by the 31st May 2024. 

Despite the extension, the EA & SEPA are strongly encouraging that obligated producers make “all reasonable endeavours” to submit their packaging data by the original reporting dates (1st October 2023 and 1st April 2024). 

This packaging data is vital to the agencies’ work and is used to enhance the modelling of illustrative base fees. These base fees are essential for obligated producers as they provide insights into potential costs associated with environmental compliance. Without accurate and timely reporting of packaging data, the agencies cannot provide producers with the indicative costs they require. The more data provided and the more accurate the data is, the more precise the fee estimates will be. To assist businesses in their planning efforts, the agencies aim to share initial estimates of illustrative base fees by the end of 2023 or early 2024. 

Martin continues:

“We very much welcome the Regulatory Position Statements released by SEPA and the EA today. This extension will allow producers who are ready, to submit their H1 data following the original timetable and benefit from advance forecasts of their EPR volumes, but will now also allow additional time for producers who are having difficulties meeting the deadlines to make their data submissions as accurate as is reasonably possible.

At Clarity, thanks to the development of our IT infrastructures and the preparatory work conducted by our compliance managers we are fully prepared to support businesses in achieving the best timescales for their business planning”

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.