EPR: How your packaging is about to increase your costs

Extended Producer Responsibility (EPR) fees

Did you know that, according to government statistics, in 2023 there was approximately 12.7m tonnes of packaging waste in the UK? Of which only 64.8% could be recycled. This is part of the reasoning for the government implementing the concept of Extended Producer Responsibility (EPR) fees.

If you are a UK business that imports or supplies packaging, then you will want to read on.

What is EPR and what are my deadlines?

EPR is designed to move companies towards building a long-term circular economy by taking responsibility for the packaging material of their products. It is designed to be associated to the costs of managing household packaging waste and is determined by the type of material being used.

Only businesses deemed large are subject to the fees, while those that are small simply need to report the packaging they place on the market.

The first instalment of fees relates to the period April 2025 to March 2026 but is calculated based on 2024 packaging data, with the first invoice of fees to be issued in Autumn 2025.

If you are a small business then you need to make sure you are collating your data for the 2024 calendar year and reporting by 1 April 2025.

For large businesses, you should already have reported your data for January 2024 to June 2024 by 1 October 2024 and now you have until 1 April 2025 to report the remaining data for July to December 2024. You will need to continue reporting every 6 months and if you miss a deadline then you may need to pay a late fee.

It is worth noting that while illustrative base fees are available online based on the type of packaging and the weight used, they are only estimates, and a final fee will not be confirmed until after 1 April 2025.

What are the size criteria for EPR?

For the purposes of EPR, a small business is when either of the following apply:

• your annual turnover is between £1m and £2m and you’re responsible for supplying or importing more than 25 tonnes of packaging in the UK.
• your annual turnover is over £1 million and you’re responsible for supplying or importing between 25 tonnes and 50 tonnes of packaging in the UK.

You will be classed as a large business if both of the following apply:

• you have an annual turnover of £2 million or more.
• you’re responsible for supplying or importing more than 50 tonnes of packaging in the UK.

The definition of packaging

For the purposes of EPR, packaging is any material that is used to cover or protect goods that are supplied. It makes handling and delivering goods easier and safer. It includes anything that’s designed to be filled at the point of sale, such as a coffee cup. The definition is extended to say it includes packaging that makes goods look appealing for sale and could display a company’s logo or brand. ‘Goods’ could include raw materials or manufactured items.

Detailed illustrations of the agreed technical interpretations of different packaging types are available on the Environment Agency’s National Packaging Waste Database.

What if I am part of a group?

There are three options available here. If you are the parent company you could:

• report on behalf of the entire group – you create one account and report data on behalf of each subsidiary that supplies packaging.
• encourage individual subsidiaries to report for themselves – each subsidiary must create their own account and report independently.
• report for a mix of components – you can report on behalf of some subsidiaries, while other subsidiaries report for themselves.

How should I report my packaging data?

In short, you can submit data online through an official portal. There is also a template for the format in which you should aim to report the data. Your submission must include information about the:

• • packaging activity – this is how you supplied the packaging.
  • packaging type – if the packaging is household or non-household.
  • packaging class – whether the packaging is primary, secondary, shipment or tertiary.
  • packaging material.
  • packaging weight.

Example scenarios are also available, which indicate who is responsible for what in the supply chain. One is summarised here.

Example ERP packaging report – Imported supermarket groceries

A UK wholesaler imports broccoli from France. It sells the broccoli to a supermarket in the UK. The supermarket then sells the broccoli to consumers under its brand name. The supermarket was responsible for the import of the broccoli and makes this clear on the label.

When the broccoli arrives in the UK, it’s already wrapped in plastic film with a paper label, which has the supermarket’s brand on it. It is stored in a wooden crate.

The wholesaler takes the broccoli out and sends the crate back to France, where it is used again. The wholesaler packs the broccoli into unbranded reusable plastic trays (such as IFCO trays). They put the plastic trays onto hired wooden pallets and secure them with unbranded shrink wrap. They send the pallets to a supermarket.

The supermarket removes the shrink wrap and the pallets. They put the plastic trays onto the shelves for customers to access them. The supermarket sends the reusable plastic trays back to the wholesaler when they are empty. The supermarket recycles the shrink wrap and sends the pallets back to the hiring company.

After a consumer has bought broccoli, they remove the plastic film and label and put it into their bin.

The wooden crates do not need to be reported as they were sent to another country to be reused.

Ultimately there is a lot to do and we encourage businesses to check in what capacity this is applicable to them and review the available reporting resources online to avoid needing to ‘reinvent the wheel’.

For more information on EPR, contact us today and speak to one of our Extended Producer Responsibility specialists. We can discuss your broader requirements and identify any related considerations that may be beneficial to your company.