Ecosurety publishes response to EPR consultation

The consultation published by Defra closes on 9 October 2023 and asks stakeholders to respond to the draft Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 legislation.

Once this legislation is passed, it will repeal the Packaging Waste (Data Reporting) (England) Regulations 2023 and the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 that are currently in force.

The consultation was published on 29 July and asks respondents to read through the draft legislation to gauge whether the text makes clear the various obligations and aspects of system design under packaging Extended Producer Responsibility (pEPR).

In our view, whilst much of the drafting is understandable, there are nonetheless examples where we believe producers and other actors in the system would not be able to clearly grasp the intention of the regulations.

For instance, we think there is a risk that packaging producers may not clearly understand the packaging activities under the single point of compliance, resulting in packaging data and associated waste management fees being submitted and charged for twice, or not at all.

Have your say

The Government have stated that they will consider the responses to the consultation and make amendments to the draft regulations as appropriate. Alongside the consultation, they will also hold co-design workshops with stakeholders to address the more detailed, technical areas of the draft regulations.

We would encourage as many producers as possible to respond to the consultation. If you agree with any part of our response, rather than duplicate it, Defra have advised that you can simply reference it in your own response by stating: 'we agree with the response to this question by compliance scheme Ecosurety Ltd.'.

Read the full Ecosurety response here and understand how to submit a response.