What should you do now to prepare for packaging EPR?

You need to understand how your business is classified (often related to sales and turnover) and then clarify what your financial reporting obligations are connected to your specific category. In late 2022, the UK government launched an online tool to help you check whether your organisation has any packaging EPR data obligations. You can access the gov.uk checker by clicking here.

Outside of the UK, EPR regulation varies country by country with different fee structures, reporting obligations and categorisation of ‘producer’. Some capture e-commerce sales more coherently, and others have clearer guidance for import and export.

It’s important to note that while some governments provide helpful details on how packaging EPR will function, there may still be gaps in the information you need to be aware of. If in doubt, specialist consultancies like Root and Ecosurety can help you understand the full extent of the specific regulatory requirements that apply to your business and what you need to do to meet them.

Preparing for EPR is essential to minimise compliance and commercial risk. Actions and reporting requirements vary by country, as does turnover and tonnage of packaging placed on the market, so understanding what kind of organisation your business is classed as will inform you on how often and what information you will need to report.

The UK government, for example, has published the majority of details about the implementation, with updates usually published here. A Compliance Scheme Register of 3rd Party Organisations who can help with reporting can be found here.

Larger organisations under packaging EPR tend to pay higher fees overall and, in the UK, are likely to be experiencing a significant increase in financial obligations as a result of the new changes in EPR compared to the previous packaging regulations.

It is not possible to know your exact EPR costs in advance due to so many variables and unknowns, including confirmation of waste management fees and their modulation by country and future PRN market performance. Given the scale of the potential increase in costs, however, it is advisable to inform your organisation’s senior leadership with an estimation of your EPR costs based on the existing data you have to hand. This will help your organisation understand and appreciate the impact that packaging EPR will have on it and hopefully inform strategic decisions that could help you to prepare and start to reduce your liabilities.

While some countries, like Germany, have no minimum sales threshold for EPR, other countries do. In the UK, for instance, both small and large organisations have significant data collection and reporting requirements under packaging EPR, with increased complexity and frequency compared to the previous regulations. In this case, you must collect this data for all the packaging you handle or supply from 1 January 2023. The size of your organisation will determine when you must report it.

You need to ensure you can accurately complete the data recording and collection requirements by the specified deadlines or risk a penalty charge.

Having this data to hand also means you can leverage it to inform any strategic decisions you make to improve your packaging and possibly reduce your EPR liabilities and environmental impact.

• Identify any weak points or gaps in your existing data that may prevent you from accurately reporting your data on time.
• Make sure you know where your biggest challenges lie by identifying the areas where you have missing, incomplete or inconsistent data. Only then can you efficiently and systematically improve your data.
• Establish processes to gather data internally and externally. Gathering the required data in the first place from your supply chains and internal departments may well be your biggest ongoing challenge.
• Get processes in place to ensure you efficiently request the right data at the right time from the right sources.
• Contact your data sources as soon as possible so they understand what you need from them and when.

It is critical that you understand what data you need to collect. For more on this subject, 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.