EPR (Extended Producer Responsibility) regulations are you ready?

Will it affect you?

It might if you:

  • supply packaged goods to the UK market under your own brand
  • package goods for another UK organisation (this includes putting plants in pots)
  • use ‘transit packaging’ to protect goods during transport so they can be sold to UK consumers ( delivering plants in trays or boxes)
  • import products in packaging (young plants from abroad)
  • own an online marketplace
  • hire or loan out reusable packaging
  • sell empty packaging.

What might I need to do?
Under the new regulations you may need to:

  • collect and submit data on the packaging you handle and supply (it is likely your customers will ask for this)
  • pay a waste management fee
  • buy packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet your recycling obligations (currently PRNs are very expensive and the price fluctuates so difficult to budget for)
  • 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 on the GOV.UK website. https://www.gov.uk/guidance/packaging-waste-prepare-for-extended-producer-responsibility

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 it all sound a bit complicated, we can help

We held a EPR discussion online meeting 18th January

We asked Aidan Gill Environment Policy Adviser (Soils, Waste, Environmental Permitting) from the NFU to attend the meeting, to help you understand your obligations.
We are still waiting from Defra the final draft of the regulations so if you are confused you are not alone.
The one thing you need to do is start recording packaging data now.