Defra released a first Guidance document on how UK organisations can prepare for extended producer responsibility (EPR) for packaging.

The guidance outlines who needs to take action, what you need to do and details on what packaging data to collect and submit.

Who needs to take action

The regulations will apply to all UK organisations that handle and supply packaging.

You must take action to comply if all the following apply:

  • you’re an individual business, subsidiary or group (but not a charity)
  • you have an annual turnover of £1 million or more (based on your most recent annual accounts)
  • you’re responsible for over 25 tonnes of packaging in a calendar year (January to December)
  • you carry out any of the packaging activities listed (check the guidance document for detailed packaging activities in scope)

What you need to do

Under the new regulations, you may need to:

  • collect and submit data on the packaging you handle and supply
  • pay a waste management fee
  • buy packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet your recycling obligations

The steps you must take to comply with the regulations will depend on whether you are classed as a ‘small’ or ‘large’ organisation. This is based on:

  • your annual turnover
  • how much packaging you handle and supply each year

Please check the guidance document for further information on data submission periods relevant to your organisation.

If you sell packaged goods or empty packaging in the UK, you may also need to submit ‘nation data’. This is information about which country in the UK your packaging has been sold, hired or loaned in. You must submit nation data if you’re responsible for any of the following:

  • selling any filled packaging to consumers
  • selling empty packaging to UK organisations that do not need to comply with the regulations
  • selling empty packaging directly to consumers in the UK
  • hiring and loaning out reusable packaging
  • owning an online marketplace that allows other organisations to sell their empty packaging and packaged goods to UK consumers
  • importing packaging to the UK that you discard without selling or exporting it

You must submit your nation data for the 2023 calendar year by 1 December 2024.

If you miss the deadline, you may need to pay a penalty charge.

Collecting and submitting your packaging data

Your organisation should start preparing now to capture your packaging data. Your data submission must include the weight of:

  • individual materials in the packaging you handle and supply
  • materials used in your ‘primary’, ‘secondary’ and ‘transit’ packaging
  • packaging likely to become household or non-household waste
  • packaging likely to end up in street bins

The EPR scheme administrator will use your 2023 data to calculate your waste management fees for the financial year 2024 to 2025.

The regulator will use your 2023 data to calculate the amount of PRNs and PERNs you must buy to cover your recycling obligations for the 2024 calendar year.

From 2025, the EPR scheme administrator will adjust your waste management fees depending on the cost of recycling the materials used in the packaging you handle and supply.

How to report material type

You must collect data on the weight of individual material types used in the packaging you handle and supply. Give all weights to the nearest tonne (1,000kg).

You should categorise your data by the following materials:

  • aluminium
  • fibre-based composite
  • glass
  • paper or cardboard
  • plastic
  • steel
  • wood
  • ‘other’

Other materials could include:

  • bio-degradable plastics – compostable plastics made of plant-based products
  • cork
  • cotton
  • flax-based products
  • nitrile
  • rubber
  • silicone

You must report each material type separately. For example, you may report that you have handled and supplied 20 tonnes of paper and 5 tonnes of plastic.

You must also state how much of each material is used in the ‘primary’, ‘secondary’ or ‘transit’ packaging you handle and supply.