Following the amendments to the packaging EPR data reporting regulations, which came into force in all four nations on the 1 April 2024, Defra have released new guidance on packaging EPR, which has now been published on Gov.uk.
The updates are included on the following pages on Gov.uk:
1. Packaging data: what to collect for extended producer responsibility.
2. Extended producer responsibility for packaging: who is affected and what to do (this page includes mostly minor wording changes to align with the main guidance).
Changes to the Packaging data: what to collect for extended producer responsibility page are as follows:
- links to the regulators’ ‘Agreed positions’ documents have been added. The principal aim of these documents is to provide assistance to those who are obligated by the Data Regulations. They describe the provisions of the Data Regulations and how they should be applied by producers and compliance schemes.
- clearer guidance on ‘established in the UK.’
- references to the list of large producers, to be published in April.
- new section named ‘changes to the data you must report from 2024’ gives a high-level summary.
- new section named ‘When to collect and report your data for 2024’ explains collection periods, deadlines and how to report your 2024 data.
- new section on packed/filled data for 2023/24, explaining the rules about packaging that has a packaging manufacturers brand on it.
- ‘Imported packaging’ has two new sub-sections covering:
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- changes to the rules around imported secondary and tertiary packaging
- packaging which you purchase from an overseas business, but is packed by a UK third party, where you may become the ‘first UK owner (this should still be reported as an importer).
- ‘Supplied as empty’ has new sub-section on the 2024 rules about supplying empty packaging to a large organisation.
- ‘Packaging that commonly ends up in public bins’ has been updated to: For 2024, straws are no longer on the list of items that end up in public bins.
- ‘Drink containers’ now includes clarifications of how the existing guidance deals with the classification of drinks containers and their ancillaries, along with a new section on the rules for 2024 onwards.
- Regulation 17A introduces a one-year transitional provision that all allows producers to discount a proportion of the packaging from their recycling obligation in the first year, if packaging has already been reported under the 2007 regulations. For more detail on how to determine this amount of packaging and how to report, please refer to page 37 in the pEPR Agreed Positions and Technical Interpretations version 4, produced by the environmental regulators.
New guidance on Extended producer responsibility for packaging: how to assess household and non-household packaging has been published separately.
We advise you to check that you have all the information you need for extended producer responsibility and should you wish to discuss any of the above in more detail, please reach out to your account manager or speak to one of our advisors on +44 (0)1865 721375 to find out how we can help.
