Progress continues towards packaging EPR clarity

While the basic framework for packaging Extended Producer Responsibility (EPR) reform has been known for some time, the finer details surrounding how the policy will operate continue to emerge.

Increased recent communications and decision-making from government mean producers can start preparing with greater confidence ahead of the first data submission for large organisations in Q3 of this year, albeit with some key details yet to be confirmed. Outlined below are the most important recent developments producers should be aware of.

Government engagement with stakeholders

Industry has been vocal in its concerns over the lack of clarity surrounding packaging EPR, and the short timeframe in which to get prepared. Government started to address these issues in the last few months by engaging with stakeholders in 'Visioning Sprints' and fortnightly Business Readiness Forums. Thérèse Coffey, the environment secretary, recently said she is also undertaking a “deep dive” into EPR to start tackling stakeholder worries.

Hopefully, much-needed light will be shed soon on the less-than-clear aspects of the new system. This includes the requirement for annual nation-data submissions and how the required information can practically be acquired. It’s also important that we get detailed guidance as soon as possible around producer obligations under the single point of compliance and how this works in complex supply chains.

At the end of 2022 government also released an online packaging EPR checker tool for organisations to determine if they have any packaging EPR obligations and required actions. It is important that organisations determine now if they have any required actions as data about their packaging for EPR reporting needs to be collected from 1 January 2023.

Waste management fee offsetting

Under packaging EPR a waste management fee will be charged to producers for packaging that is classed as household or street-binned packaging, in addition to their PRN obligation. This will be used to fund the collection and sorting of packaging waste by local authorities.

It was recently made clear that producers can reduce their EPR waste management fees in two ways, the first being ‘self-managed’ waste offsetting. This is applicable when a producer undertakes collections of waste household packaging themselves and sends it for reprocessing, for example via in-store customer take-back of plastic bags. There are a number conditions attached however – the material must not be commonly collected by local authorities for recycling, the producer must have reported the same material as being handled or supplied, and they must have evidence of it being recycled.