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EPR – Extended Producer Responsibility – Guidance published

packaging

What is it all about?

The Government is passing the cost of collecting and sorting waste packaging that is found in household bins to businesses that handle packaging. This will begin in 2024.

The most recent guidance has been published here. https://www.gov.uk/guidance/packaging-waste-prepare-for-extended-producer-responsibility

It is not very detailed so you might want to read my notes too.

Who is obligated?

  • Companies who are currently covered by the ‘Packaging regs’ will continue to buy PRNs to subsidise the cost of recycling their share of packaging handled
  • Under EPR responsibilities will be shifted around so that brand owners, importers, online marketplaces and distributors of empty packaging will have to subsidise the cost of collecting and sorting waste packaging that is likely to end up in household bins
  • Sellers of packaging, distributors of empty packaging, online marketplaces, and importers of packaging likely to end up in household bins will have to report information about how much was likely to become waste by nation (England, Wales, Scotland & NI)
  • Businesses that turn over more than £1m but less than £2m and handle between 25 and 50t of packaging per year will have to register but will not have to buy PRNs or contribute to EPR.
  • Businesses using disposable paper based cups with more than 10FTE employees will have to offer a takeback bin for used fibre-based cups (coffee cups) and report the quantity collected and sent for recycling.
  • Producers and retailers of drinks containers will..Under separate Deposit Return Scheme legislation, have to contribute towards the cost of running a deposit return system.
    • It is proposed to apply to all drinks containers from 50ml to 3 litres.
    • Materials included
      • All nations will include metal & plastic drinks containers
      • England & NI will exclude glass bottles from their DRS
      • Scotland and Wales will include glass.
    • This has huge potential for confusion if not fraud.

Changes to reporting

  • A new material category to cover fibre-based containers (coffee cups)
  • Sub reporting of polymer type and other sub types is likely to be included under EPR
  • Subtype of reporting for whether the packaging is primary, secondary or tertiary
  • Reporting will extend to whether your packaging is likely to end up in domestic waste bins. And to be specific, it will be assumed that your waste ends up in the domestic stream unless you have ‘clear evidence’ to the contrary.
  • As indicated above, some businesses will have to report where their packaging ends up (England, Wales, Scotland & NI)
  • And, I did not spot it in the feedback but they may ask what colour socks you are wearing (Sorry, I got bored but decided to leave it to see who reads it all. Well done.)
  • Businesses will have to report data twice per year:
    • Jan – Jul in October
    • July – Dec in March

Costs

  • Producers will have to continue to buy PRNs until at least 2027.
  • For waste that is likely to end up in household waste bins, Brand owners, importers, online market places and distributors of empty packaging will have to contribute towards the cost of collecting and sorting that waste. This will go to the Scheme Administrator (a Government appointed body) who will in turn pay Local Authorities for collection and sorting waste, known as ‘Full Net Cost’.
    • This is likely to be around 5 – 10 times what you are currently paying for PRNs.
    • The cost of the subsidy will vary by material and reflect the ease with which it can be recycled.

Timeline

Defra have published a timeline for implementation.

  • Existing Producer responsibility
    • as usual to end of 2023 (but restart within EPR below, reporting twice per year).

 

  • Extended Producer Responsibility
    • 2022 – Companies assess whether their business is obligated for EPR in 2023
    • Sep 2023 - Company report Jan – Jun packaging handled
    • Oct 2023 - Scheme Administrator receives data (Jan – Jun ’23) & estimates initial costs. Issue invoices
    • Mar 2024 - Company report Jul – Dec packaging handled
    • April 2024 - Scheme Administrator receives data (Jul – Dec ’23) & updates costs. Issue invoices.
    • April 2024 - company pays 1st invoice to Scheme Administrator
    • July 2024 - company pays 2nd invoice to Scheme Administrator
    • Oct 2024 - company pays 3rd invoice to Scheme Administrator
    • Jan 2025 - company pays 4th invoice to Scheme Administrator
    • Jan 2025 - Scheme Administrator reconcile and calculate end of year charge / rebate
    • Jan – Dec 2024 - Compliance Schemes buy PRNs (based on data submitted Sept 2023 & Mar 2024) and invoice accordingly.
  • Repeat on an annual cycle.

Congratulations if you made it this far. If it makes you feel better, the first five emails that I receive with a subject line ‘free pin badge’ and your address in the body of text will get a free GBN logo pin badge by return.

The consultation response documents can be found here: https://www.gov.uk/government/consultations/packaging-and-packaging-waste-introducing-extended-producer-responsibility

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