Quick recap

As we’ve covered in our previous blog, Extended Producer Responsibility (EPR) is an extension of the existing UK Packaging Waste Regulations and is provisionally set to come into law on 1st January 2025. It marks an extensive change to the way UK organisations responsible for packaging carry out their recycling responsibilities.

The aim of the change is for packaging users and producers to pay the full net costs of managing and recycling the packaging waste they produce through a system of modulated fees. Previously this cost was paid for either wholly or in part by local government. The system is planned to incentivise use of recyclable materials and the ability to recycle or reuse packaging.

Final draft has been sent

The government, through Defra, announced that the final draft of the new EPR regulations ‘The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024’ has been sent to the World Trade Organisation on the 1st May 2024.

This is a significant milestone in the process of the legislation being brought before the UK Parliament in autumn for introduction on the 1st January 2025.

Submission of data

For 2023, two sets of data relating to packaging should have been collected and submitted:

• Packaging data as previously required under the 2007 Packaging Regulations for 2024 (2023) with the requirement to pay for PRNs as usual. In essence, for 2024 the existing Regulations continue to be applicable.

• Packaging data as required by the new regulations relating to EPR. No fees will relate to data collected and submitted for 2023. For any company that hasn’t completed this so far, they have until 31st May 2024. Anyone who misses this deadline could be penalised with a fine.

For 2024, all obligated producers must collect and submit packaging data relating to the new EPR regulations. It was announced in July 2023 that the first EPR payment will be deferred to 1st October 2025, a year later than the original date of 1st October 2024.

More information is available on the Government website. Please bear in mind, these regulations are being updated as the legislation is finalised so please check with your own legal and compliance bodies.

If you have any questions, or require further guidance, please contact us. We look forward to helping you.