Extended Producer Responsibility (EPR) -Update
Keeping up to date with progress on Extended Producer Responsibility (EPR) is a full-time occupation. It has been blighted with delays leaving many businesses confused. Since my last post in May, we don’t seem to have moved on much further except those that need to comply, should have submitted period 1 (Jan 2024 – June 2024) data to their chosen compliance scheme (https://sustainableleadersinbusiness.co.uk/extended-producer-responsibility-its-a-wrap/ ).
To recap EPR is a policy approach aimed at making producers responsible for the entire lifecycle of the products they place on the market, particularly their end-of-life stage. This includes the costs associated with the collection, recycling, and disposal of packaging waste. The goal is to incentivise producers to design more sustainable products and reduce the environmental impact of packaging waste. The incentive being reduced associated regulatory costs.
Who It Affects
EPR affects a wide range of businesses in the United Kingdom (UK), including:
- Manufacturers: Companies that produce goods and package them for sale.
- Importers: Businesses that bring packaged goods into the UK market.
- Retailers: Those who sell packaged goods directly to consumers.
- Online Marketplaces: Platforms that facilitate the sale of goods, including those from non-UK businesses.
- Packaging Suppliers: Companies that manufacture or import empty packaging for use by other businesses.
Current Situation and Hold-Ups
The implementation of EPR in the UK has faced several delays. Originally, businesses were expected to start paying EPR fees in 2024, but this has been deferred to 20251. The primary reason for this delay is the complexity involved in setting up the National Data system, which is essential for tracking and reporting packaging data.
Reasons for Delays
Collecting accurate and comprehensive data from all affected businesses has proven difficult. There are still many businesses that are not fully prepared to report the data required. The amount of data needed and the technical issues to develop robust and secure IT systems has been extremely challenging.
The Government has extended the consultation period with stakeholders to ensure that the system is workable and fair for all parties concerned.
Timeline for Rollout
January 2025: Main EPR Statutory Instrument to come into force including LP financing obligations; SP reporting obligations; and nation reporting obligations. Defra’s release of Local Authority Waste Management base fees expected.
End of March: regulatory deadline for compliance schemes to submit LP P1 2024 data and SP 2024 data.
April 2025: Deposit Return Scheme (DRS) Deposit Management Organisation (DMO) to be appointed
Summer 2025: Waste Management Fees on 2024 to be confirmed.
October 2025: First LA waste management fee invoice expected by the Governments Scheme Administrator
2027: DRS operational
What Businesses Need to Do Annually
- Jan/Feb Large Producers period 2 (Jul – Dec 2024) data due
- Jul/Aug Large Producers period 1 (Jan – Jun 2025) data due
- Small Producer data collection period (Jan – Dec) 2025
- Nation data collection period (Jan – Dec) 2025
- Pay fees
Conclusion
The UK’s EPR scheme represents a significant shift in how packaging waste is managed, placing greater responsibility on producers to ensure their products are sustainable throughout their lifecycle. While the implementation has faced delays, the extended timeline allows businesses more time to prepare and comply with the new regulations. By 2025, the full impact of EPR will be felt, driving improvements in packaging sustainability and reducing the environmental footprint of packaging waste.
EPR can seem overwhelming, if you have any specific questions or need further details, feel free to ask!
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