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Packaging EPR

From 2023 packaging producers will be expected to bear the full net cost recovery of the packaging they place on the market. Are you prepared?

What is packaging EPR?

Packaging EPR is a policy tool whereby producers are made significantly responsible for the packaging they place on the market at the end of its life. Government first stated their intention for a UK packaging EPR system in the 2018 Resources and Waste Strategy. The overall purpose is to ensure long term planning and investment into sustainable material use and recycling infrastructure, and to fulfil the ‘polluter pays principle’. All producers will be expected to pay into the system and bear the ‘full net cost recovery’ of the packaging they place on the market.

Am I affected by packaging EPR?

If you are a producer of packaging, including an importer, you will be impacted by EPR and your compliance costs will inevitably increase. The current producer responsibility system exempts small producers by a 50 tonne placed on market and £2 million turnover de minimis, but this may change as Government aims to capture all packaging within the new system.

The impact of EPR and full net cost recovery

The latest EPR consultation has confirmed that there will be a single point of compliance. Government have proposed that there will be six categories of obligated producers who will have varying obligations: brand owners, importers, distributors, online market places and sellers. Costs will be recovered throughout the supply chain as additional charges are made. Some businesses that are not obligated in the current system may find they are.

Businesses in the new system will also no longer be required to purchase evidence of recycling based on tonnage, but instead fund the full net cost of collection, recycling, disposal, the clear-up of littered packaging, and communications. This will be through mechanisms such as a deposit return scheme and modulated fees. These are all currently subject to consultation. A plastic packaging tax will also penalise those not using at least 30% recycled content in their plastic packaging placed on the market.

A further aspect of the EPR framework will be the introduction of a binary standardised labelling system. The details of this will be confirmed after the current consultation, but all producers will be required to adapt their packaging formats.

Find out more about the new EPR mechanisms below:

Modulated fees

If you are a producer of packaging in the UK you will be affected by modulated fees, used to financially incentivise the use of more sustainable and recyclable materials.

Plastic packaging tax

The plastic packaging tax will directly affect producers of packaging that is predominantly plastic by weight with less than 30% recycled content - are you ready?

Deposit Return Scheme (DRS)

The DRS is set to be implemented in Scotland in 2022 with England following in 2024. All producers of in-scope drink containers will be required to meet a collection target set by government. Are you affected?

Consultations

The second consultations for packaging Extended Producer Responsibility and a Deposit Return Scheme were released by UK Governments in March 2021. Find out why you should have your say.

What do I need to do now?

Government is consulting on the packaging EPR measures in the first half of 2021, so the details surrounding the methodology and processes producers will have to adhere to are not yet fully known. However, we strongly advise you to start preparing now to ensure that your business is ready for when packaging EPR is implemented. Here is what you need to do:

1. Make sure you stay fully informed

It is important that you stay abreast of the latest updates from government as they will directly impact your business, from the official consultation responses to the draft and implemented legislation. Being fully informed means you can ensure your wider team not only know the impacts to expect, they can respond proactively sooner. We inform our members of important milestones and updates and we always publish the latest news on our website.

2. Respond on the consultations

The consultations are open to responses from anyone, not just technical experts, and it is crucial there is a wide range of respondents with an equal representation of views to achieve the best regulatory outcome. Join our free EPR consultation webinar on 22 April and our free DRS consultation webinar on 23 April to get up to speed on what you need to know and how to respond.

3. Ensure you are capturing the right data

EPR will require much higher levels of data reporting than the current packaging compliance requirements, but you don't need to wait until EPR is implemented to start this. By collecting this level of detail now, you will achieve full transparency of the potential impact on your business and you will be able to efficiently comply when EPR comes into force. Our team can get you started with this requirement now, contact us to find out how.

4. Start modelling your costs

Once you have control of your data, you can model your costs to assess the full impact of EPR before it comes into force. Our team are on hand to enable you to do this with the minimum of fuss, contact us to find out more.

5. Adapt your strategy ahead of the legislation implementation

With full control of your data you can start to take strategic decisions about how to reduce the environmental impact of your packaging and your EPR costs. Our team are again on hand to help you do this, contact us to find out more.

We are here to support you

if you think you are affected by packaging EPR, we can assist you through data assurance and analysis, including cost forecasting to model how your business will be impacted so that you can be fully prepared - to help you budget for the increased costs and take steps to reduce the environmental impact of your packaging.

Request packaging EPR support now

Future services and support

We are developing further services to support our members with the future requirements of EPR and we are working with government and industry to seek further clarification on the mechanics and future requirements. We will continue to offer guidance as legislation is updated and we will let our members know what further support we will provide in the future.

Find out more about existing packaging legislation

Find out if existing packaging producer responsibility legislation applies to you, what you need to do and how we can help.

Find out more