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You'll probably have heard about packaging Extended Producer Responsibility (EPR).  But do you really know what it is and the impact it will have on your business?  Here's our 60-second guide to get you up to speed. 

If you work in retail, you probably deal with a lot of packaging. You might be importing products in packaging or supplying packaged goods under your own brand or third-party brand. Whether you are food or non-food, Bricks and Mortar, multichannel or pureplay, if you sell packaged goods to UK consumers, you need to be aware of the changing regulatory regime around packaging and how it may impact your business.  

What is it?

Extended Producer Responsibility (EPR) is a regulatory regime which makes producers (brands) more responsible for their post-consumer product. Packaging has been governed by an EPR since 1997 (Packaging Regulations) and its main purpose is to guarantee the collective responsibility of businesses to contribute towards the cost of recycling and recovery of packaging. 

Why Is it important?

Packaging EPR affects businesses who own and perform a relevant activity on the packaging they handle, by bringing in specific obligations for businesses as part of their ‘producer responsibility’ if they meet the thresholds. Packaging compliance is a legal obligation that retailers need to be fully aware of.  

Why Is it important now?

It is important to be aware of the current changing regulatory landscape around household packaging.  

UK Government is introducing important changes to improve packaging recycling rates: 

  • by drastically changing the overall financing of the system (shifting the full financial burden onto brand owners). What does this mean for you? If you fall within the revised thresholds, from April 2024, you will have to pay additional fees to your current PRNs, called EPR fees, to cover the disposal costs of packaging waste management. 
  • by introducing new packaging data reporting requirements. What does this mean for you? You will have to report to the UK Regulators more detailed packaging data information and more frequently 
  • By introducing eco-modulation based on the recyclability of your packaging from 2025. What does this mean for you? You will have to submit more detailed information regarding your packaging specs (ex: polymer level) and its recyclability, this will subsequently inform whether some of your EPR fees will increase or decrease (materials hard to recycle are expected to attract higher fees). 
  • By mandating specific recyclability labelling on packaging by 31 March 2026, and 31 March 2027 for plastic films and flexibles. What does this mean for you? You will have to incorporate the mandatory labelling requirements in time on your consumer facing packaging, including the Recycle Now ‘swoosh’ and relevant wording (recycle/do not recycle). 
  • By obliging some businesses to provide a takeback of fibre-based composite cups from 2024. What does this mean for you? If you sell drinks and beverages in cups, you will be required to set up of dedicated bin for separate collection of cups. 

Catch-up on all the details with our on-demand webinar Get Ready for the New Packaging Data Reporting Rules

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What do members need to do?  

  • Check if you are in scope of packaging regulations, and therefore should be compliant with the legal requirements  
  • Check who is dealing with your packaging compliance: this is either done in-house or externalised to a third party (packaging compliance scheme).
  • Check if you fall under the newly revised thresholds for EPR fees and/or reporting requirements (like the per nation reporting)
  • Anticipate the financial implications of the new packaging EPR fees for your business, in addition to you PRN bill  
  • Anticipate packaging labelling changes ahead of 2026
  • Make sure you have the best and most accurate packaging data capture and details to inform the recyclability of your packaging  

 

What are we doing to help members with it?

We guide members through the implementation of the new packaging EPR rules, advising them on the requirements and key compliance deadlines to be aware of, and provide insightful technical and policy support on various packaging related issues. We host regular member meetings to update members with the latest updates and developments.

We continuously share feedback to UK Government on the practical challenges that businesses are facing with the new reporting requirements and conduct in a wider policy and political engagement on packaging EPR. 

More information on packaging EPR available on via the links below: 

PACKAGING EXTENDED PRODUCER RESPONSIBILITY (EPR): JANUARY 2023 REQUIREMENTS 

PACKAGING EPR: FAQS ON DATA REPORTING REQUIREMENTS FROM JANUARY 2023 

PACKAGING EPR: GENERAL MEMBER UPDATE, MARCH 2023