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Update on UK Extended Producer Responsibility (EPR

Date: 10/02/2023

Extended Producer Responsibility: UK

The UK government issued a consultation on Extended Producer Responsibility (ERP) for packaging in 2021. This has now concluded, and proposals are in place to implement EPR in the UK. For smaller organisations, this means collecting data on packaging supplied to the UK market throughout 2023, with registration and reporting from early 2024. For larger organisations there is a shorter timeframe, data should be collected from 1 Jan 2023 with registration and reporting from July 2023.

Key Dates

From

1 Jan 2023

All affected organisations to collect packaging data

July 2023

Large Organisations

Register and Report

Early 2024

Small Organisations

Register and Report

Who is affected by the regulations?

Your organisation will be affected if all of the following apply:

  • UK business (not a charity)
  • Handle and supply packaging to either consumer or B2B
  •  
  • Annual turnover £1M+
  • Responsible for 25 tonnes of packaging per annum
  • You carry out any of the packaging activities

You may also be affected and need to act if you are involved in Packaging Activities, meaning you:

  • supply packaged goods to the UK market under your own brand
  • place goods into packaging that’s unbranded when it’s supplied
  • use ‘transit packaging’ to protect goods during transport so they can be sold to UK consumers
  • import products in packaging
  • own an online marketplace
  • hire or loan out reusable packaging
  • supply empty packaging

Check if this applies to your organisation:

There is an online checker you can use to determine whether your organisation is affected, and the level of your responsibilities: https://report-packaging-data.service.gov.uk/obligation-checker/type-of-organisation

Nation Data

Nation data is information about which country in the UK your packaging has been sold, hired, loaned, gifted or discarded in. Depending on your organisation, you may need to gather and report this data. The online checker tool above will help you to identify if this is the case.

Size of the organisation and responsibilities

Your responsibilities are different depending on the size of your organisation (small or large). Additional compliance options exist for parent companies, groups, or subsidiaries. Based on latest annual accounts, companies with a turnover of under £1M do not need to report packaging data.

Small organisations

You are a small organisation if either of these apply:

  • Annual turnover is between £1M-£2M and you’re responsible for handling and supplying more than 25 tonnes of empty packaging or packaged goods through the UK market
  • Annual turnover is over £1M and you’re responsible for handling and supplying between 25 tonnes and 50 tonnes of empty packaging or packaged goods through the UK market

The responsibilities of a small organisation are:

Record data about packaging you handle/supply

from 1 Jan 2023

Create an account & register your organisation

from Jan 2024

Pay a Fee to environmental regulator

From 2024

Reporting: Submit data about packaging handled/supplied throughout 2023

Submit from 1/1/24 to 1/4/24

Submit Nation Data

(If required) By December 2024

Large Organisation

You are a large organisation if both of these apply:

  • you have an annual turnover of £2 million or more
  • you’re responsible for handling and supplying more than 50 tonnes of empty packaging or
    packaged goods in the UK

The responsibilities of a large organisation are:

Record data about packaging you handle/supply

from 1 Jan 2023

Create an account & register your organisation

from July 2023

Pay a Fee to environmental regulator

 

Buy PRNs or PERNs to meet recycling obligations

 

Report data on empty packaging and packaged goods

 

Reporting required Every 6 months

 

For the period Jan-Jun 2023:

report between Jul 23-1 Oct 23

 

For the period Jul-Dec 2023:

report between 1/1/24-1/4/24

 

Submit Nation Data

(If required) By December 2024

Compliance Scheme

A company may choose to register with a compliance scheme (a 3rd party organisation who will help an
organisation to meet their EPR requirements).

There is a list of approved schemes here: http://npwd.environment-agency.gov.uk/PublicRegisterSchemes.aspx

More information

More information about UK EPR can be found on the UK Government site here: https://www.gov.uk/guidance/packaging-waste-prepare-for-extended-producer-responsibility