The landscape of extended producer responsibility (EPR) for packaging in the UK has evolved, with significant changes outlined in the latest guidance released on 23 January 2024.

These updates affect all organisations involved in the supply or import of packaging. Here’s what you need to know to stay compliant.

EPR for packaging: key changes and deferral of fees

If your organisation is impacted by extended producer responsibility for packaging, it is essential to be aware of the latest developments.

The most noteworthy update is the deferral of EPR for packaging fees for a year. In 2024, you won’t be required to pay any EPR fees; however, compliance with reporting guidelines for 2023 remains mandatory.

It is crucial to continue adhering to previous regulations and fulfilling any outstanding fee obligations.

Identifying affected organisations: are you in scope?

The reach of the regulations extends to all UK organisations engaged in the import or supply of packaging. To determine if your organisation falls within the scope, consider the following criteria:

  • Annual turnover of £1m ($1.27m) or more, based on the most recent accounts.
  • Responsibility for more than 25 tonnes of packaging in 2022.
  • Engagement in specific packaging activities such as supplying goods to the UK market under your own brand, placing unbranded goods into packaging, importing products in packaging, owning an online marketplace, hiring reusable packaging, or supplying empty packaging.

Reporting and compliance obligations for different packaging activities

Understanding how your specific packaging activities align with EPR regulations is crucial. Here’s a breakdown of obligations for various scenarios:

  • Supplying goods under your brand: If your organisation supplies goods with your brand to the UK market, you must take action. This includes any distinctive marks associated with your brand.
  • Unbranded packaging: If you place goods into unbranded packaging, whether for your own organisation or another, compliance measures apply.
  • Importing products in packaging: If your organisation imports products in packaging from outside the UK and supplies them to the UK market, you must comply with EPR regulations.
  • Owning an online marketplace: Operating an online marketplace that facilitates non-UK businesses selling goods into the UK requires action under EPR for packaging.
  • Hiring or loaning reusable packaging: If your organisation engages in hiring or loaning reusable packaging, compliance is necessary.
  • Supplying empty packaging: If you manufacture or import empty packaging and supply it to a non-large organisation, you are subject to EPR regulations.

Adapting to the changing landscape

The packaging sector must adapt to the evolving EPR regulations in the UK. Whether you’re a large or small organisation, understanding your obligations, reporting deadlines, and potential fee structures is essential.

Stay informed about the latest guidance, and if needed, seek assistance from compliance schemes to navigate the intricacies of extended producer responsibility for packaging.

Remember, even though fees are deferred, reporting your packaging data for 2023 remains a priority.