Extended Producer Responsibility -its a wrap
What, where, how?
It used to be the case that February was the one month in the year where there was a frenzy of data collation and calculation for businesses that had to submit packaging data to fulfil the Producer Responsibility (Packaging Waste) Regulations (PWR). This is slowly being superseded by the Extended Producer Responsibility Regulations (EPR) which meant yet another stressful month of data gathering. And, what’s more I can look forward to yet another session in the autumn. So what is EPR? Here’s my short guide.

What is the point of EPR?
In the United Kingdom, the concept of Extended Producer Responsibility (EPR) has been established to shift the environmental responsibility of packaging waste towards producers. The aim is to incentivize businesses to reduce packaging waste, design for recyclability, and support recycling efforts.
Who Needs to Comply?
EPR regulations apply to all UK organisations that import or supply packaging. If your business meets the following criteria, you need to comply with EPR rules:
- You’re an individual business, subsidiary, or group (excluding charities).
- Your annual turnover is £1 million or more.
- You were responsible for more than 25 tonnes of packaging in 2022.
- You can carry out any packaging activities, such as supplying packagied goods under your own brand, placing goods into packaging, imported products in packaging, owning an online marketplace, hiring or loaning out reuseable packaging, or supplying empty packaging.

It is likely that if you had to submit data under PWR then you will have to comply with EPR.
What Information to Gather?
Businesses must collect and report data on the packaging they are responsible for. This includes the amount and type of packaging supplied and the measures taken to reduce, reuse, or recycle it.
Here’s a checklist of the data that UK businesses need to gather for Extended Producer Responsibility (EPR) submissions for the year 2024:
- Packaging Activity Data: Record all packaging activities, including production, import, and supply of packaging materials.
- Packaging Type Data: Classify the packaging by type, such as primary, secondary, or tertiary packaging.
- Packaging Class Data: Identify the class of packaging, which could include single-use, reusable, or recyclable classifications.
- Packaging Material and Weight Data: Document the materials used in the packaging and their respective weights.
- Household and Non-Household Packaging Data: Differentiate between packaging intended for household use and non-household use.
- Drinks Containers Data: If applicable, collect specific data on drinks containers supplied.
- Reusable Packaging Data: For reusable packaging, track the number of times each item is reused.
- Self-Managed Waste Data: If you manage your own waste, report the quantities and treatment methods.
- Nation Data: Report which country within the UK the packaging is supplied in and where it is discarded.
Remember to maintain detailed records and ensure accuracy in your data collection.
What are the Submission Periods and Deadlines for 2024?
For the year 2024, businesses will not have to pay any EPR fees for packaging. However, they must still follow the guidance and report their packaging data for 2023. The deadlines for reporting packaging data and the specific submission periods have been deferred , and businesses are advised to check the latest Government Guidance.
Are there any penalties?
The penalties for incorrect data submission under the Extended Producer Responsibility (EPR) regulations in the UK can be significant. While specific penalty amounts are not detailed, generally, businesses can face fines and legal action for non-compliance or providing false information. For the year 2024, it’s been noted that regulators will set penalties for missed deadlines. Additionally, the english and scottish regulators have decided not to take enforcement action as long as organisations submit their (2023 data) packging data by May 31st, 2024. This suggests that there is a grace period for submissions, but failing to meet this expended deadline could result in penalties.
How does the cost of EPR compare to PWR?
In a report by PwC, the cost of Extended Producer Responsibility (EPR) to businesses in the UK, compared with the existing packaging waste regulations, is expected to be significantly higher. Under the current Producer Responsibility Obligations (Packaging Waste) Regulations, businesses pay a relatively small fee towards the recovery and recycling of packaging waste. However, with the introduction of EPR, the costs are anticipated to increase substantially. The EPR system aims to make producers responsible for the full net cost of managing packaging at the end of its life. This shift in responsibility is projected to result in compliance costs for producers increasing by 6 to 20 times. The annual costs to the industry under the current system are between£200-£300 million, but with EPR, this could inflate to nearly £3billion per year.
In addition, producers will be required to pay an EPR fee towards the costs of collecting and managing household packaging waste, which is currently borne by local authorities. This is estimated to be around £1.2 billion per year. Businessees will ont have to pay any EPR fees for packaging for 2024 but fees will continue for PWR.
EPR can seem overwhelming for the newcomer especially for the small businesses that need to supply data. Don’t sit there struggling, pick up the phone or email me and I’ll help you.
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