What is packaging EPR?

New Extended Producer Responsibility (EPR) measures for packaging were introduced on the 1st of Jan 2023 in the UK. Here, we outline the basics of EPR from a global perspective, with Ecosurety providing some context for UK EPR.

EPR is designed on the Polluter Pays principle – meaning those who place packaging on the market are responsible for paying for the collection and management of the packaging they use. Compliance companies, like Ecosurety, process data about producers’ packaging, submit it to the regulators and procure evidence of recycling on behalf of the producers, with the funds raised used to improve recycling performance and infrastructure.

Updates to UK EPR will be fully implemented by 2027. While the final allocation of fees collected through EPR is not confirmed yet in the UK, the intended spend includes infrastructure improvements, like increased collection of flexibles, public information campaigns, and litter clean-ups.

Globally, EPR is used for a range of product and packaging types to promote the recovery and reuse of finite and highly polluting materials. EPR is designed to incentivise producers to use less packaging and move away from single-use non-recyclable formats, with eco-modulation planned – so producers pay more for non-recyclable packaging. Eco-modulation drives higher fees for hard-to-recycle packs and lower fees for easy-to-recycle packs.

There is currently minimal financial incentivisation through the modulated fee approach for businesses to favour reusable packaging over single use. This is something which we hope will change in the future. We also predict that fee modulation will factor in Carbon weighting at some time in the future.

In Europe, EPR will be mandatory in all EU nations by 2024 and is already live in some states in the US. In Asia, for many countries, EPR is planned to be in place in the next three years:

– Singapore, Malaysia and China’s full rollout is planned by 2025
– South Korea, Taiwan and Japan EPR is planned by 2026
– Thailand, Vietnam and the Philippines are also due to have EPR in place in the next few years

We asked Ecosurety to share some helpful insights about how EPR affects companies providing packaged goods to the UK market.

Packaging EPR measures impact most ‘producers’ (organisations that handle or supply packaging), and it is a legal requirement to comply with them. In most instances, the single point of compliance and any fees are weighted on the brand-owner or importer, but it can also impact online marketplaces, packers/fillers, service providers of reusable packaging and sellers of empty packaging.

Since the beginning of 2023, you may have experienced a significant increase in activity, including data collection and reporting, with financial obligations starting from 2024. Your actions depend on whether you meet the packaging EPR threshold criteria set by the UK government and if you are classed as a small or large organisation.

As a minimum, all organisations – including those under the EPR threshold – will need to comply with mandatory labelling requirements from 2026, which requires you to notify consumers whether or not the packaging can be recycled.

At the end of 2022, the UK government launched an online tool to check if you have any packaging EPR data obligations. To visit the gov.uk checker, please click here.

Obligated organisations have various required actions under packaging EPR. Depending on your organisation’s size and activities, these may include:

– Creating an account on the government portal (which is yet to go live)
– Capturing details about the packaging you handle and supply
– Reporting detailed data to government (generally via a compliance scheme) about the packaging you handle or supply, whether imported or purchased/manufactured in the UK
– Paying scheme administrator fees
– Funding the recycling of packaging by purchasing Packaging waste Recycling Notes (PRNs) from recyclers
– Paying additional waste management fees for packaging likely to end up as household waste to fund local authority collections and sorting of packaging waste
– Labelling your packaging to inform consumers about its recyclability

To find out more about what your organisation should be doing now to prepare for EPR, see click on the button below.

A Root Packaging Audit is a great first step to help identify the risks across your packaging portfolio. The audit will give you the tools to build a policy-proof and commercially viable packaging strategy that will ensure you remain compliant across every territory your business operates within.

If you would like to discuss the challenges facing your business, schedule a call with a Root sustainability experts who can advise you on the steps you need to take.