On 9 January, BRC hosted a meeting on the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (commonly referenced as the Extended Producer Responsibility regulations for packaging (pEPR)) that recently passed through parliament. As of 1 January, the regulations are now in force.
Defra provided updates on the regulations, the Recyclability Assessment Methodology (RAM), and the Scheme Administrator (SA). BRC provided an outline of our recent lobbying activities and upcoming events.
You can read the key takeaways from the meeting below.
Defra Updates
The Recyclability Assessment Methodology (RAM) was published on 23 December 2024.
- From 1 January 2025, obligated producers will be required to assess the recyclability of the household packaging placed on the market and report the results of the assessment to the environmental regulator along with other reporting requirements. Producers must report H1 data in October 2025 and report H2 data in April 2026.
- This data will be used by the Scheme Administrator (SA) to modulate fees.
- Defra confirmed that they plan to engage on modulated fees through Q1 2025.
- Members are encouraged to join Defra’s pEPR Version 3 Base Fees and RAM Methodology and Approach to Reporting Webinar on Thursday 16 January at 14:00 until 16:00. You do not need to register – join the Teams meeting here.
- Defra noted members comments on the level of technical detail required to be reported, which, in some cases, is not currently collected by compliance schemes. Defra took an action to increase efforts to engage with compliance schemes on RAM reporting in 2025.
BRC asked about the interactions and differences between PRNs and EPR. Defra confirmed that they will continue to run in parallel – PRN covers all packaging whilst EPR covers household packaging. If you have any further details on your challenges relating to this point, please contact Naomi.
BRC asked about introducing statutory recycling targets similar to those introduced in Wales. Defra stated that it is not the focus for the short/medium term.
Defra stated that there will potentially be a delay to certain reporting requirements including:
- Nation sales data
- Self-managed packaging waste
- Carrier bag data
Defra signposted relevant accounting guidance following requests for further guidance on invoicing and accounting.
For specific technical reporting clarification, members were advised to ask the RPD helpdesk at EPRCustomerService@defra.gov.uk or by calling 0300 060 0002.
The Scheme Administrator for pEPR will be formally launched at Packaging Innovations at NEC in February 2025. BRC will be attending this event.
- There will continue to be four advisory stakeholder groups including the continuing Steering Group – of which BRC is a member – a specialist communications and behaviour group, a specialist RAM group, and a specialist Efficiency & Effectiveness (E&E) group.
- Adverts will be published at the end of the month to become part of one of these advisory groups. The role will be a voluntary role and will require a three-year term. Defra will be running a staggered recruitment process.
- The SA will be going through its second wave of recruitment of formal staff soon. They will be advertising senior executive roles. Defra requested we shared the roles when they become available.
BRC Activity Update
BRC listed its extensive lobbying activity regarding the ask of a postponement to EPR fees. You can read more details here.
BRC flagged an event for members to learn about the activity on the pEPR Producer Responsibility Organisation (PRO). Event details and how to register can be found here.
It was noted in the meeting that we are supportive of the PRO and its development but are limited in how much resource we can spend on the details of its development.
Next Steps
BRC Actions
- Share recruitment details for the SA and Advisory Stakeholder Groups with members when available.
- Attend the SA launch in February at Packaging Innovation. If you are planning to attend, feel free to let Naomi know.
- Continue with lobbying efforts.
Member Actions
- Join Defra’s pEPR Version 3 Base Fees and RAM Methodology and Approach to Reporting Webinar on Thursday 16 January at 14:00 until 16:00. You do not need to register – join the Teams meeting here.
- Join the BRC members call on the pEPR Producer Responsibility Organisation (PRO). Event details and how to register can be found here.
