Understanding Household and Non-Household Waste Definitions under UK Packaging Extended Producer Responsibility Legislation

Under the EPR system, it is mandated that those who place packaging into the UK market bear the full net cost for the collection, sorting, and treatment of packaging waste.

To ensure the legislation has clear legal operability, the definitions of Household and Non-Household waste differ from the traditional understanding of what is perceived as a household waste item.

In this article Clarity outlines one of the many differences between the current system and EPR, one of which is the categorisation of waste types between EPR Household waste (HHW) and EPR Non-Household waste (NHHW). Packaging producers obligated under EPR will be required to report on their HHW and NHHW twice a year to the Scheme Administrator (TBC) as well as paying a Local Authority Waste Management fee on their EPR HHW.

Household packaging is all primary and shipment packaging except where this is supplied to a business who is the final user of that packaging. This means that some packaging will be classed as household packaging, even though it may be unlikely to end up in a household waste bin.

If there is more than one link in the supply chain between the responsible producer and the final user of the packaging, the packaging must be classed as household packaging even if the final user of the packaging is a business. For example, where packaging is supplied to a wholesaler who then supplies it to the end-consumer, this would be classed as household packaging under EPR.

Binned waste will also be included under the EPR household waste definition.

Defining household packaging uses its position in the supply chain, and this sometimes means that other, traditionally NHH, packaging is captured within this.

Non-household packaging is packaging which is supplied to a business which is the final user of that packaging.

As explained above, all primary and shipment packaging is classed as household waste however, if it is supplied to a business who is the final user of that packaging which can be clearly evidenced, this packaging can be classed as EPR non-household packaging.

Where an obligated producer cannot provide sufficient evidence, all primary and shipment packaging is to be treated as household packaging.

When determining whether a piece of packaging is classed as household, it is important to remember that defining household packaging under EPR is based on the supply chain, not whether the waste arises in the household or not.

The implication of this is increased costs on packaging that is aimed at business end use but is not supplied directly to that business by the reporting EPR producer.

With packaging compliance costs due to increase significantly, it is crucial that packaging producers obtain the relevant evidence of their non-household waste to avoid additional costs under EPR.