Spring 2025 EPR policy round up

Changes to EPR reporting 

Given the final set of 2024 packaging data has now been submitted, which was reported in line with the now revoked EPR data reporting regulations, all packaging supplied in 2025 will be reported under the ‘main’ EPR statutory instrument.  

This means a few changes to the reporting rules under EPR, outlined in the Environment Agency’s latest version of their technical guidance. The changes include a redefinition of ‘drinks container’ to 150ml-3l (from 50ml), a change to the definition of shipment packaging, and a new reporting condition for brand-owners. We recommend obligated producers familiarise themselves with these changes to the reporting in time for the first submission of 2025 data, in October. Our packaging EPR guidance articles in the Ecosurety Hub website have been updated accordingly.

EPR statutory Instrument Amendments  

Government have identified and drafted amendments to the EPR statutory instrument, that they are expecting to be passed by the end of this year and apply from 2026 onwards. The amendments were notified to the European Union on 23 April, and include provisions to appoint a Producer Responsibility Organisation (PRO) and to extend the scope of producer ability to offset EPR waste management fees via the ‘self-managed consumer waste’ data submission.  

However, the amendments don’t include a hoped-for modification to the definition of household packaging – meaning for the foreseeable future only direct B2B sales of primary formats can be evidenced as non-household and avoid the EPR waste management fees. The amendments don’t include any provision for mandatory labelling, or additional costs to packaging reported as ‘commonly binned’ either, which may be drafted for future iterations of the regulations.  

We’re here to help

If you have any questions relating to any of the above, please contact your account manager or help desk directly. If you are not yet a member of Ecosurety, please contact our team for assistance.