The EPR is designed to transfer the responsibility and the full net cost of managing packaging once it becomes waste. This includes 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.
Who do the EPR regulations apply to?
How to comply with the EPR scheme
What are the cost implications of EPR?
Extended Producer Responsibility (EPR) in the EU – What You Need to Know
Key Differences Between UK and EU EPR
What UK Businesses Selling in the EU Need to Do?
Data collection takes time - so start now
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).
You need to take action if all of the following apply:
Definition: If your annual turnover is between £1m and 2 m 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.
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.
From 2025 you may have to do the following based on your 2024 data.
Source: Packaging waste - prepare for extended producer responsibility
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.
The UK is not the only region implementing Extended Producer Responsibility (EPR) regulations. The European Union has introduced EPR schemes as part of its Circular Economy Action Plan, focusing on reducing waste and ensuring that producers take financial and operational responsibility for the entire lifecycle of their products.
EU's Packaging and Packaging Waste Regulation (PPWR) which was adopted on 24th April 2024, is a significant development. It aims to harmonise packaging rules across the EU, increase recycling rates, and reduce packaging waste.
It includes requirements for packaging recyclability, recycled content, and labeling.
All EU Member States must implement EPR for packaging waste in line with the Packaging and Packaging Waste Directive. However, individual countries may have different regulations, reporting requirements, and fee structures. The key objectives of the EU EPR framework include:
Ensuring producers cover the full costs of waste management – This includes collection, sorting, and recycling, with costs varying based on recyclability.
Encouraging eco-design and waste prevention – By linking fees to recyclability, the EU EPR scheme incentivises businesses to adopt more sustainable packaging solutions.
Standardising labelling and consumer information – Several countries, including France, require clear sorting instructions on packaging to improve recycling rates.
Boosting recycling targets – The EU has set ambitious recycling targets, including a 65% recycling rate for packaging waste by 2025 and 70% by 2030.
The EU Waste Electrical and Electronic Equipment (WEEE) Directive is another key EPR regulation focused on the lifecycle management of electronic products. Producers of electrical and electronic equipment (EEE) are required to finance the collection, recycling, and disposal of electronic waste (e-waste). Additionally, products must be designed for durability, repairability, and recyclability to minimize waste generation.
Batteries Regulation (which entered into force 17 August 2023) imposes EPR obligations on manufacturers and importers of batteries, ensuring they take responsibility for end-of-life battery collection and recycling.
The European Union is leading the way in implementing EPR for textiles as part of its EU Strategy for Sustainable and Circular Textiles. The EU Waste Framework Directive is being revised to make EPR for textiles mandatory in all Member States by 2025.
The framework is designed to make producers responsible for the entire lifecycle of their textile products, from design and production to post-consumer disposal and recycling. The aim is to reduce textile waste, promote circularity, and encourage sustainable practices within the fashion and textile industries.
While both the UK and EU EPR regulations aim to shift financial responsibility onto producers, there are key differences:
Scope and Fees: The EU EPR framework applies across all Member States, but national variations exist. Some countries charge eco-modulated fees, meaning businesses pay more for packaging that is harder to recycle.
Reporting Obligations: Businesses selling products across multiple EU markets must comply with each country’s specific reporting and registration requirements, which can vary significantly.
Obligations for Online Retailers: In the EU, online marketplaces may be considered producers and could be required to take responsibility for compliance, whereas the UK primarily holds brand owners accountable.
If your business sells packaged goods in the EU, you must ensure compliance with EPR requirements in each country where your products are placed on the market. This may include:
Failure to comply with EU EPR regulations can lead to penalties, sales restrictions, and reputational risks. Therefore, UK businesses operating in the EU should take proactive steps to understand their obligations and implement compliance strategies.
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.
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.”
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.