The new changes include making producers of packaging responsible for the full net costs of the packaging life cycle.
Although the EPR changes may not impact all of our members, those that handle and supply packaging to consumers and businesses may be impacted. The new EPR regulations aim to make producers of packaging responsible for the full net costs of the packaging life cycle.
Packaging regulations affect many of our members, including egg packers, dairy processors, and the horticulture sector. Similarly, our members handle a large amount of packaging waste, including cardboard, paper, wood, metal and plastic, as part of their business operation. While the EPR for packaging draft regulations has not yet been publicly released, a brief summary of the main points is outlined below.
Further information and definitions can be found on GOV.UK's Packaging waste: prepare for extended producer responsibility page.
Are you impacted?
You may be impacted if you:
- supply packaged goods to the UK market under your own brand
- package goods for another UK organisation
- use ‘transit packaging’ to protect goods during transport so they can be sold to UK consumers
- import products in packaging
- own an online marketplace
- hire or loan out reusable packaging
- sell empty packaging.
What are the changes?
Under the new regulations you may need to:
- collect and submit data on the packaging you handle and supply
- pay a waste management fee
- buy packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet your recycling obligations
- submit information about where your packaging has been sold, hired, loaned, gifted or discarded – this is called ‘nation data.
What you need to do depends on whether you’re classed as a ‘small’ or ‘large’ organisation.
This will be based on your annual turnover and how much packaging your handle and supply each year. The definitions of these can be found in the link above on the GOV.UK website.
Small organisations will not need to pay any fees, but they will need to record and submit their data. Large organisations will be required to pay a base fee for the scheme’s first year and then pay a modulated fee for the following years.
What is the time frame?
All organisations will need to be collecting the correct packaging data from 1 January 2023.
Small organisation:
You’ll need to submit your data between 1 January 2024 and 1 April 2024.
Large organisation:
You’ll need to submit data every 6 months.
For the period January to June 2023, submit data between 1 July 2023 and 1 October 2023.
What packaging data will I need to collect?
Your data submission must include the weight of:
- individual materials in the packaging you handle and supply
- materials used in your ‘primary’, ‘secondary’, ‘shipment’ and ‘transit’ packaging
- packaging likely to become household or non-household waste
- packaging likely to end up in street bins.
The scheme administrator will use your 2023 data to calculate your waste management fees for the financial year 2024 to 2025.
The regulator will use your 2023 data to calculate the amount of PRNs and PERNs you must buy to cover your recycling obligations for the 2024 calendar year.
Does my location matter?
You may have to submit data about which country in the UK your packaging has been sold, hired, loaned or gifted in.
More information on whether you have to submit nation data is available at the GOV.UK website linked above.
Nation data for the 2023 calendar year must be submitted by 1 December for 2024.