Extended Producer Responsibility | All you need to know
Here is your handy guide to all things Extended Producer Responsibility (EPR). Find out what you need to know, including why it’s important, whether it applies to you, timelines, what to do and much more.
- What is EPR?
- Why is EPR important?
- What is full net cost recovery?
- What are modulated fees?
- EPR timeline
- Why is EPR being implemented?
- Does EPR affect your business?
- What data will you need to collect?
- How much will EPR cost?
Getting help with EPR
The implementation of Extended Producer Responsibility (EPR) is imminent and obligated businesses are well advised to begin preparing now.
Extended Producer Responsibility (EPR) is a new UK legislation that will replace the current Packaging Waste Regulations with a phased implementation from 2023. It is an environmental policy that requires producers to pay the total cost of dealing with the waste they produce from when it is placed onto the market to the end of its life.
These new regulations build on the existing Packaging Waste Regulations which have been in place since 1997 and it is hoped that their implementation will achieve a reduction in the environmental impact of products throughout their life cycle. The idea is that if you produce the pollution, then you should pay for the costs of the impact it can have on the environment as well as on people’s health. So, under EPR proposals, packaging producers will be responsible for the entire cost of recycling the household packaging they place on the market including the cost of collection, treatment, and of course recycling.
What is EPR?
Extended Producer Responsibility (EPR) is a policy approach under which producers are given a significant responsibility – financial and/or physical – for the treatment or disposal of products and/or packaging at the end of its life.
Who invented EPR?
It all started with Thomas Lindhqvist in 1990 at Sweden’s Lund University, when he introduced the EPR concept in a report to the Swedish Ministry of the Environment.
Why is EPR important?
Designed to divert and reduce waste, EPR closes the loop on materials management, recovering product/packaging waste when the user discards it and reusing it as a raw material to produce a new product or packaging material.
What is full net cost recovery?
Full net cost recovery seeks to make obligated producers responsible for the entire cost of recycling the packaging they place on the market; this includes the cost of collection, treatment and recycling. Producers will be required to pay the costs of dealing with packaging waste that arises with the householder and on the go packaging disposed of in street bins.
This is a fundamental step change away from the existing Packaging Waste Regulations, which requires obligated producers to pay towards ensuring there is enough capacity to meet the recycling targets. Under full net cost recovery obligated producers will see a significant rise in their compliance cost. It is envisioned that the cost of compliance will rise from approximately £350 million to £1.7 billion under the proposed EPR system.
What are modulated fees?
A modulated fee system will be introduced from 2025 to provide discounts depending on the environmental impact of the packaging placed on the market. Packaging that can be easily recycled will attract lower EPR fees compared to hard to recycle packaging. This will therefore provide financial incentive for producers to use more sustainable materials in their packaging.
Government will hopefully confirm the structure of modulated fees next year. Nevertheless, it is clear that less sustainable and hard to recycle materials will incur higher costs, whereas sustainable packaging which is easily recyclable will be rewarded with lower fees.
There will be a phased introduction of EPR, beginning with the gathering of data from January 2023 by producers for:
- fibre-based composite
- paper or cardboard
- ‘other’ (broken down by key material type)
Why is EPR being implemented?
In 2018 the UK adopted the Circular Economy Package (CEP), meaning that the UK is committed to the full net cost of collecting, sorting, treating, and recycling to be funded by producers rather than central government taxation. EPR is set to help local councils by funding collections and more effective management of packaging waste; it is the UK’s answer to meeting the CEP and encourages the use of easy-to-recycle materials and penalises the use of hard-to-recycle materials.
Does EPR affect your business?
If you are a producer first placing packaging on the UK market, whether UK sourced or imported, it is likely you will be affected by EPR.
You must take action to comply if all the following apply:
- you’re an individual business, subsidiary, or group (but not a charity)
- you have an annual turnover of £1 million or more (based on your most recent annual accounts)
- you’re responsible for over 25 tonnes of packaging in a calendar year (January to December)
- you carry out any of the packaging activities
You may need to act if you do any of the following:
For impacted organisations, costs will inevitably increase under an EPR system, plus more complex data recording and increased demand for submission requirements.
Organisations who place over 50 tonnes of packaging on UK markets and have a turnover that exceeds £2 million annually are liable for the additional costs and data requirements under EPR.
Organisations that do not meet the 50 tonnes of packaging placed on the UK market and have below a £2 million annual turnover are exempt from the payment aspect of EPR; however, under the new system, these smaller producers may be required to gather and submit detailed packaging data. Any organisations with more than a £1 million turnover who handles 25 tonnes of packaging annually will have reporting obligations.
What data will you need to collect?
You’ll need to collect data about the packaging you’ve handled and supplied through the UK market.
There should be four parts to the data you collect about your packaging. These are:
You may also need to collect nation data. This is information about where your packaging has been sold, hired, loaned, gifted or discarded in the UK.
Large organisations need to report data every six months. Small organisations report data once a year.
How much will EPR cost?
As soon as we can, we will give you an indication of what your fees will be in 2024.
From 2025 the waste management fee will vary depending on the type of materials you have reported. Your fee will be lower if you use materials that are easier to recycle.
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Getting help with EPR
We will be working with all our current clients on a one-to-one basis to prepare for the upcoming changes, but please do reach out to your account manager if you have any questions.
If you are new to the world of EPR, please speak to one of our advisors on +44 (0)1865 721375 to find out how we can help you take the complexity out of environmental compliance!
How to prepare for EPR?
To prepare for EPR and achieve a seamless transition to the new system, you should:
What is Ecoveritas?
The easiest and most comprehensive way to manage environmental data and reporting needs.
What does Ecoveritas do?
Ecoveritas is an environmental compliance data specialist that provides a range of tools and expertise to brands, retailers, and supply chains to minimise the environmental impact of their packaging efficiently.
To meet the complex challenges of managing environmental compliance reporting, Ecoveritas offers a unique combination of consulting, data and software that helps companies around the globe take the next step in their sustainability journey.
Our team takes a fresh approach to the environmental compliance market by adding years of supply chain and technical development expertise to an experienced environmental data team to provide SaaS-based services.
Our mission is to make it easy for companies to understand their obligations, get compliant and respond appropriately through reduction, substitution, and recycling.
- Extended Producer Responsibility Data Management & Reporting
- Plastic Tax Data Management & Reporting
- EPR Horizon Scanning
- EPR Consulting
Ecoveritas can help you prepare your packaging for EPR and to get ready to record data from 1st January 2023.
Navigating environmental legislation is time-consuming. For businesses operating across numerous countries, the issue is even more complex.
We can help;
- Identify how your business can best prepare to minimise EPR impacts
- Help you gather and capture the granular data EPR requires.