Extended Producer Responsibility (EPR) is an environmental policy which extends a product’s responsibility of a product to the post-consumer stage of a product’s lifecycle. In the UK, new EPR Regulations apply to all UK organisations that import or supply packaging on the UK market.
Packaging is defined as ‘any material that is used to cover or protect goods that are sold to consumers.’ It makes handling and delivering goods easier and safer. It also includes anything that’s designed to be filled at the point of sale, such as a coffee cup.
Packaging also makes goods look appealing for sale and may display a company’s logo or brand. ‘Goods’ could include raw materials or manufactured items.
Who is impacted by EPR?
If you do any of the following packaging activities, you may be required to comply with EPR:
It is important to first understand whether you are classed as a ‘small organisation’ or a ‘large organisation.
You are classed as a ‘small organisation’ if either of the following apply:
You are classed as a large organisation if both of the following apply:
Turnover should be based on your most recent annual accounts. The total weight of packaging is across a calendar year (January - December) and is packaging that you supplied through the UK market and/or imported and then discarded in the UK market.
Small Organisations
If you are classed as a ‘small organisation’ you must record data about the empty packaging and packaged goods you supply or import in the UK from either 1st January 2023 or the 1st March 2023. If you have data from 1st January 2023, this should be collected, otherwise data from 1st March 2023 onwards should be collected. You will also need to report data about empty packaging and packaged goods you supplied and imported via the UK Gov portal and pay a fee to the environmental regulator. Fees to the environmental regulator have been deferred a year and will apply from 2025 onwards, instead of 2024.
2023 packaging data does not need to be reported, it only needs to be collected. 2024 packaging data needs to be reported and submitted by April 2025 to the environmental regulator. Small organisations are only required to report data once per year via https://www.gov.uk/guidance/report-packaging-data
Large Organisations
If you are classed as a ‘large organisation’ you must also record data about the empty packaging and packaged goods you supply or import in the UK from either 1st January 2023 or the 1st March 2023. If you have data from 1st January 2023, this should be collected, otherwise data from 1st March 2023 onwards should be collected. You will also be required create an account on the above gov.uk link, to pay a waste management fee, pay scheme administrator costs, pay a charge to the environmental regulator, obtain PRNs (Packaging Waste Recycling Note) or PERNs (Packaging Waste Export Recycling Note) to meet your recycling obligations.
In England, Scotland & Northern Ireland. data collected from January to June 2023 should be submitted by 1st October 2023. Data collected from July to December 2023 should be submitted by 1st April 2024. If you are based in Wales, you should submit data collected from July to December 2023 should be submitted by 1st April 2024 and you can also include data from January to June 2023 if you have it.
Large organisations are required to report data every 6 months via https://www.gov.uk/guidance/report-packaging-data
Parent companies and their subsidiaries have various options on how to comply and register for EPR. There are a number of different ways to register:
Parent companies should be registered when some of its subsidiaries do not meet the turnover and tonnage requirements in their own right but they do meet the requirements when combined. The parent company will comply with EPR on behalf of its subsidiaries in this case.
Data Collection
When reporting data you must include the following information about the:
Fees
The EPR packaging fees have been deferred for 1 year. They will now start from October 2025 instead of October 2024.
At present, the fees payable have not been published.
You must still report packaging data for 2023 as this will provide a future indication of fees.
PRNs & PERNs
A PRNs (Packaging Waste Recycling Note) or PERNs (Packaging Waste Export Recycling Note) is evidence that the packaging waste has been recycled. These can be obtained from accredited reprocessors. You will find a list of accredited reprocessors on the UK gov website. Re-processors are responsible for recycling packaging waste. PERNs can be obtained from accredited exporters.
