The UK Government are committed to protecting the environment and have pledged to achieve Net-Zero carbon emissions by 2050. This signals their strong intent to introduce Extended Producer Responsibility for packaging.
But what is Extended Producer Responsibility? When does it come into effect and how does it affect the packaging industry? In this article, we will explore all there is to know about Extended Producer Responsibility.
What is Extended Producer Responsibility (EPR)
Extended Producer Responsibility (EPR) is a new UK legislation that will replace the current Packaging Waste Regulations with a phased implementation from 2023. It is an environmental policy that requires producers to pay the full costs of dealing with the waste they produce from when it is placed onto the market, through to the end of its life.
It is hoped that this will achieve a reduction in the environmental impact of products throughout their life cycle. The idea is that if you produce the pollution, then you should pay for the costs of the impact it can have on the environment as well as on people’s health. So, under EPR proposals, packaging producers will be responsible for the entire cost of recycling the packaging they place on the market including the cost of collection, treatment, and of course recycling.
Will the Extended Producer Responsibility affect my business?
The guidance states that this change will affect all UK organisations that handle or supply packaging. For some further information, handling activities are explained under the current Producer Responsibility Obligations (Packaging Waste) Regulation 2007.
The actions that will need to be taken all depends on the size of your organisation. A small organisation is classified as the following:
- A small organisations annual turnover is between £1 million and £2 million and is responsible or handling and supplying 25 + tonnes of empty packaging or packaged items throughout the UK market in a calendar year.
- Alternatively, a small organisations annual turnover is over £1 million and is responsible for handling and supplying between 25 tonnes – 50 tonnes of empty packaging or packaged items through the UK market in a calendar year.
As for a large organisation -
- Annual turnover is £2 million or more and responsible for handling and supplying more than 50 tonnes of empty packaging or packaged products in a calendar year.
What actions need to be taken under Extended Producer Responsibility?
The actions that will need to be taken depends on the size of your business.
In order to comply:
- Record data about all the empty packaging and packaging products you handle and supply through the UK market as of 1st January 2023.
- Register for the EPR for packaging online service of which registration opens in 2024 for small organisations.
- Submit data about the empty packaging and packaged products you handled or supplied through the UK market throughout 2023.
The data for 2023 will need to be submitted between 1st January 2024 and 1st April 2024. Any missed payments will result in a penalty charge.
Similar to small organisations but with some differences. In order to comply your organisation needs to:
- Take steps to record data about the empty packaging and packaged products you handle and supply in the UK from 1st January 2023.
- Register for the EPR for packaging online service from April 2023
- Pay a fee for the environmental regulator
- Buy packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNS) in order to meet recycling obligations
- Submit the data about empty packaging and packaged goods you handled or supplied through the UK market.
Large organisations will need to submit data every 6 months. Additionally, any organisations selling goods in the UK including distributors, online marketplaces, retailers, and sellers may also need to submit ‘nation data’. Nation Data is information about which country in the UK your packaging has been sold, hired, or loaned in. This means that these types of companies will need to assess the packaging they handle in greater detail than they do currently. The 2023 data for this will need to be submitted by December 2024.
What packaging activities come under the Extended Producer Responsibility regulation?
So you may be wondering what packaging activities will be coming under this new regulation. Below we have provided the current full list:
- Packaging own-brand products to sell to UK consumers
- Using a third party to package and sell own brand goods to UK consumers
- ‘Transit packaging’ that is used to protect goods during transport so that they can be sold to UK consumers
- Importing own-brand and third-party packaged products into the UK to sell to consumers (unless doing so on behalf of a third party – such as a supermarket).
- Allowing third parties based outside of the UK to sell packaged products or empty packaging through an online marketplace that you own
- Hiring or loaning out reusable packaging to UK third parties
- Making and selling empty packaging to third party organisations that do not need to take action under the regulations.
According to Gov.UK, your organisation should start preparing now to capture your packaging data. The data submission must include the weight of:
- Individual materials in the packaging you handle and supply
- Materials used in your primary, secondary, and transit packaging
- Packaging likely to become household or non-household waste
- Packaging likely to end up in street bins
The scheme administrator will then 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 operations for the 2024 calendar year. Then from 2025, the scheme administrator will adjust your waste management fees depending on the cost of recycling the materials used in the packaging you handle and supply.
For the full information and guidance about the Extended Producer Responsibility regulation, visit Gov.UK.
Extended Producer Responsibility UK and Swiftpak
The cost to business will rise substantially, with the current system costing UK companies between £200-300 million a year. Extended Producer Responsibility (EPR) is predicted to cost around £2.7bn, which will mean costs for companies could increase 10 to 30 times more.
With 45 years of experience in the packaging industry, at Swiftpak we wanted to explore the Extended Producer Responsibility UK so that our customers will know what to expect. If you have any questions about this new regulation, you can either visit the gov.uk website or contact us today and we will be happy to help you as much as we can.