Biffa, a UK waste management services provider, has published a practical guide to the upcoming rules on Extended Producer Responsibility (EPR).
- In July 2023, the UK Government pushed back the EPR scheme by a year from October 2024 to 2025.
- The measure imposes on businesses that handle packaging to fund the total cost of managing packaging waste (from production to removal) in addition to their current liability.
- Because the data required is much more detailed than any previous disclosures, companies face a challenge in understanding where to start, and how to implement, a collection strategy within their operations.
In July 2023, the UK Government pushed back the EPR scheme by a year from October 2024 to 2025. This means that EPR costs will be implemented in 2025 and the modulated fees will not be introduced until October 2026.
Designed to ensure that packaging makers pay for the cost of recycling their products, the measures were postponed “in light of the pressure facing consumers and businesses in the current economic context”. Even though the deadlines have been extended, companies should start collecting data as soon as possible to ensure they are prepared.
What is EPR?
The rule is part of a group of policies which has the potential to place carbon cost at the centre of the UK’s sustainable growth across the next 20 years. It employs data intelligence and financial incentives for packaging to aid the transition to a circular economy by creating accountability for materials, rewarding the reduction and reuse of waste as catalysts for change.
UK businesses that handle packaging will need to fund the total cost of managing packaging waste (from production to removal) in addition to their current liability. This means paying for all packaging they introduce to the UK market, plus additional fees for waste disposed of by household consumers. For example, a baked beans manufacturer must cover the costs of the pallet and shrink wrap used to send its beans safely to the supermarket, along with the additional household fees for the tins their customers recycle at the end of life.
Who is affected?
Businesses responsible for new packaging rules are defined as ‘producers’. They choose the materials which are brought to the UK market as packaging and disposed of as household waste. Producers include:
- Brand owners, whose name, trademark, or distinctive features appear on an item of filled packaging;
- Importers, which import filled packaging into the UK, or the first person in the UK who takes ownership of the packaging;
- Packers/fillers, which pack goods into unbranded packaging
- Distributors, which manufacture or import empty packaging and sell that packaging to anyone who isn’t an obligated producer;
- Online marketplaces, which operate an online marketplace whereby non-UK sellers can sell filled or empty packaging to UK consumers.
Producers are divided into two categories, small and large. Small businesses have an annual turnover of £1-2 million and handle over 25 tonnes of packaging, while large businesses’ annual turnover exceeds £2 million and they look after over 50 tonnes of packaging. If a company has an annual turnover below £1 million and handles less than 25 tonnes of packaging, they are not obligated under EPR.
How should companies prepare?
According to Biffa’s guide, data gathering is the first and most important step in getting the policy off to a strong start. All businesses obligated under EPR will need to submit their first round of data by October 2023 or January 2024, depending on their size.
The data required is much more detailed than any previous waste disclosures. Businesses face a challenge in understanding where to start, and how to implement, a collection strategy within their operations.
Companies should consider five factors: which producer types they are, exclude exports to avoid overpaying, have up-to-date weights of their packaging, report the correct level for each piece of packaging, and declare if it is household or non-household.
The guide said: “EPR will change packaging in the UK in ways that extend beyond data collection. How we act on that data will be crucial to successfully realising a UK circular economy.”
Even though the Goverment’s delay is allowing more time, ‘producer’ companies should act sooner rather than later to ensure that their data is in order. This information will not only allow them to be EPR-compliant, but will also provide an important insight into their operations and how they can be transformed to adhere to circularity principles, as well as avoiding greenwashing.
Businesses that enact meaningful changes and become more circular will reap benefits, as stakeholders – investors, clients, consumers – are increasingly seeking to align their spending with their values.