What is the Extended Producer Responsibility (EPR)?
The EPR is designed to transfer the responsibility and the full net cost of managing packaging once it becomes waste; collection, sorting, treatment, as well as the actual recycling of packaging, from the taxpayer to brand owners and producers. The aim is that the direct cost of specific packaging recycling should be met by those placing the packaging onto the UK market.
Producers and importers will continue to fund the actual recycling of their packaging waste through purchasing of Packaging Recovery Notes (PRNs). The EPR will fund the collection, treatment and sorting costs of packaging waste through direct payments from those producers.
The main aim of EPR is to transfer the cost to producers in order to incentivise more sustainable packaging choices. EPR will also support local authorities by funding more effective management of packaging waste and will help the UK meet their objectives under the Circular Economy Package (CEP).
Who does EPR apply to and what should I do?
You need to take action if all of the following apply:
- you’re an individual business, subsidiary or group
- you have an annual turnover of £1 million or more
- you’re responsible for over 25 tonnes of packaging in a calendar year
- you carry out any of these:
- packaging own-brand products to sell to UK consumers
- using a third party to package and sell own-brand goods to UK consumers
- using 'transit packaging' to protect goods during transport so they can be sold to UK consumers
- hiring or loaning out reusable packaging to UK third parties
What you need to do
Small organisations
Definition: If your annual turnover is between £1m-£2m and you supply less than 25m tonnes of packaging, OR, your packaged goods are less than £1m and you supply between 25-50 tonnes of packaging or packaged goods.
- You should have recorded all data on the empty packaging and packaged goods you handle and supply through the UK market in 2023 but you don't have to report it.
- Collect data on all of the empty packaging and packaged goods you handled or supplied through the UK market in 2024 ready for reporting.
- Register for the EPR packaging online service and submit 2024 data by 1st April 2025.
Large organisations
Definition: If your annual turnover is £2 million or more AND you are handling and supplying more than 50 tonnes of empty packaging or packaged goods in the UK.
- You should have recorded all data on the empty packaging and packaged goods you handle and supply through the UK market in 2023.
- You should have also created an online account for your organisation on the EPR packaging online service and submitted your 2023 data.
- October 2024 - deadline to submit your data from Jan 24 to Jun 24
- April 2025 - deadline to submit your data from Jul 24 to Dec 24.
Actions and Fees
From 2025 you may have to do the following based on your 2024 data.
- Pay a registration fee to the environmental regulator.
- Obtain PRNs or PERNs to meet your recycling obligations.
- Pay a waste management fee
- Pay scheme administrator costs.
Source: Packaging waste - prepare for extended producer responsibility
Advice to Businesses: 3 Steps To Take
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Conduct a Packaging Review
Understanding your packaging use is the first step in preparing for compliance. Audit the packaging materials your business uses, including those used in production, transportation, and retail. Break down the materials by type (e.g., plastic, cardboard, metal) and weight. Analyse packaging for opportunities to reduce waste. Check the recyclability and how widely recycled your chosen packaging materials are. By analysing your packaging footprint now, you can not only prepare for accurate reporting but also identify opportunities to switch to more sustainable, cost-effective materials that could reduce your fees in the long term. -
Evaluate Your Data Collection Systems
Implement robust systems to track and report on the materials, components, and packaging used in your products. Accurate data will be critical for compliance and cost calculation. Reliably automate data collection and validation where possible. -
Keep up to date with any developments on the timeline
Staying informed about updates to the timeline for the EPR is essential for ensuring compliance. Regularly monitor announcements from the UK Government to stay ahead of any changes in deadlines, reporting requirements, or fee structures of EPR.
What are the cost implications of EPR?
Under EPR, responsibility will now sit with one company. Producers will fund the full net cost of the collection, sorting and treatment of packaging waste. These costs are roughly estimated to be around £1.4bn.
EPR is changing the way that costs of compliance and recycling are currently spread throughout the supply chain. Under the current producer responsibility system, these costs are shared throughout the supply chain, with a percentage responsibility allocated at different points. For the part of EPR that funds the recycling process, the biggest change is in the percentage responsibility for PRNs. It is estimated that once the costs are spread amongst those obligated under the new EPR, the costs to these businesses is likely to exceed 5 times their current cost obligation, if not more.
It is estimated that EPR could generate up to £1.8bn. £1.2bn of which will be passed to Local Authorities to fund the collecting, managing, recycling and disposing of household packaging waste.
Data collection will take time - so start now
EPR means businesses now have to collect more complex data on their packaging, likely introduce a new reporting format and submit data more frequently. It will take time to gather this data, so the sooner you start the better.
Ensure you are capturing the data you need in an easy to use format, automated wherever possible. Our team can help you streamline your compliance process under EPR.
With the right solution, compliance and compliance reporting can quickly become second nature.
How Segura can help
Download our UK EPR Factsheet for a recommended roadmap to compliance
We have outlined the key elements of the regulation and provided a roadmap to compliance in one handy document. Download it now here.
Data Collection
Through Segura’s order management module retailers can identify and track packaging orders and facilitate real-time orders through nominated suppliers. In addition, the platform can capture the necessary data such as packaging weight, material, type and class. Capturing the necessary product information required for the Due Diligence Statement.
Reporting
Segura’s business intelligence tool makes it easy to capture, manage and export packaging data.
"The Segura platform gives us a deeper insight into our suppliers and the products and components they are providing us. This enables us to minimise risk and ensure products continue to comply with ever-tightening legal requirements. Segura’s ability to centralise all of our data and evidence onto a single platform allows the various teams to use the same robust data to underpin their decision-making, and provides the business and consumers with the confidence that we are working towards the same goals.”
About Segura
Segura Systems is a UK-based SaaS company enabling ethical, sustainable and efficient multi-tier supply chains.
Segura provides n-tier mapping, transparency, traceability, visualisation, compliance and reporting. Segura sits in the centre of your supply chain management structure creating a central repository for all your supply chain, ESG-related data and evidence, including from third-party data sources.
To learn more why not contact us today.
