Extended Producer Responsibility (EPR) measures for packaging are coming into force soon, with a lowered obligation threshold and new requirements.
The EPR measures are a policy tool to make producers significantly more accountable for packaging they handle or supply. The aim is to incentivise the use of less and more easily recyclable packaging and ensure that adequate funding is raised from producers to collect and recycle their packaging material when it becomes waste.
Those with an obligation will need to start collecting detailed data on their packaging from 1 January 2023. Registration, data reporting and financial obligation requirements will also start in 2023 or 2024, depending on the organisation size.
It is important to note that the de minimis threshold has been lowered compared to the previous packaging regulations. This means that if you handle or supply packaging in any way, it is critical that you check now if your organisation is impacted by EPR and has any required actions to fulfill.
Your organisation will have required actions under packaging EPR if it:
- Is an individual business, subsidiary or group
- And has an annual turnover of £1 million or more
- And is responsible for more than 25 tonnes of packaging in a calendar year
- And carries out any of these activities:
- supply packaged goods to the UK market under your own brand
- place goods into packaging that’s unbranded when it’s supplied
- use ‘transit packaging’ to protect goods during transport so they can be sold to UK consumers
- import products in packaging
- own an online marketplace
- hire or loan out reusable packaging
- supply empty packaging
If you think you meet this main threshold criteria, you can find out more your required actions on the gov.uk packaging EPR web page. This page also has further information about the list of packaging activities in the threshold criteria that you need to check.
Please note that our sister compliance scheme Ecosurety also has useful advice available to help you make sense of the new regulations, including when they are happening and what you need to do – find our more here.