The Environment Agency (EA) issued a Regulatory Position Statement (RPS) on 11 February, outlining their enforcement approach to two aspects of the EPR reporting requirements.
The RPS states that if producers do not submit their 2024 or 2025 nation of sale data, or their self-managed organisation waste figures relating to the same period, the ‘Environment Agency will not normally take enforcement action against you if you do not comply with these legal requirements’.
To be clear, it is still a regulatory obligation under the EPR legislation to collect and report this data, but if producers do not do so it is unlikely any enforcement action will be taken by the environmental regulators.
Nation of sale data, for the previous calendar year’s supply figures, is reported by 1 July in a given compliance year, other than the 2025 deadline which was extended to 1 December. Self-managed organisation waste however is reported under the main EPR submissions, by 1 April or 1 October.
The RPS will be revoked on 31 December 2026, meaning businesses will need to ensure they collect the relevant data from 1 January next year and submit it according to the deadlines, or risk enforcement action by the environmental agencies.
As these two aspects of EPR reporting only provide data for calculating national UK recycling rates, the announcement states the reason for issuing this position statement is to ‘reduce the regulatory burden of data collection and reporting obligations that have no bearing on producer disposal fees and recycling obligations’.
What should Ecosurety members do?
We encourage Ecosurety members who have self-managed organisation waste data and/or nation data ready in 2025 to submit it to us for reporting to government as normal. Obligated Ecosurety members who do not have this data ready in 2025, must ensure they are ready to report it from 2026 when the relaxation of the requirement ends.
You can find the RPS here.
If you have any questions, please countact your Account Manager, or contact the Accounts Helpdesk info@ecosurety.com.
