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EPR packaging and waste regulation to change in UK from Jan 1 2023

ERP

EPR regulation in UK will require organisations to change the way they report and recycle packaging in 2023. EPR (extended producer responsibility) rules due to come into force on January 1st 2023 will require organisations to start collecting and reporting the correct packaging data. The regulations will apply to all UK organisations that handle and supply packaging to consumers and to businesses.

You will need to report packaging data if: 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); and You carry out any of the packaging activities.

Use the UK government online service to check if you need to report packaging data

To comply with the regulations you must take steps to record data about empty packaging and packaged goods you handle and supply in the UK from 1 January 2023; create an account and register your organisation from July 2023 and pay a fee to the environmental regulator.

Packaging activities

You may need to act if you: supply packaged goods to the UK market under your own brand; place goods into packaging that’s unbranded when it’s supplied; use ‘transit packaging’ to protect goods during transport so they can be sold to UK consumers; import products in packaging; own an online marketplace; hire or loan out reusable packaging; supply empty packaging or supply goods to the UK market under your own brand.

Your organisation may need to take action under EPR for packaging if it sells packaged goods labelled with its own brand. A brand includes a logo; a trademark; any distinctive mark.  For example, a confectionery company produces packaged sweets under their own brand. It sells these sweets to a supermarket. The supermarket goes on to sell the sweets to UK consumers. In this instance, the confectionery company may need to take action. However, the confectionery company would not need to take action if it sold sweets to a supermarket, which then sold them under its own brand. In this instance, the supermarket may need to take action.

You may also need to take action if you pay another company to carry out part of the supply chain for you. For example, you may pay another organisation to do any of the following: produce goods that will be sold under your brand name; pack goods that will be sold under your brand name; place your branded goods on the UK market; import goods for you; Placing goods into packaging that’s unbranded when it’s supplied. If you place goods into packaging and that packaging is unbranded when it’s supplied, you may need to take action. This could be goods you packaged for your own organisation or for another organisation.

Importing products in packaging

You may need to take action if your organisation imports products from outside the UK that are in primary, secondary or shipment packaging and goes on to supply these products to the UK market. You may need to take action even if you discard packaging before selling the goods. You will not need to take action if you import goods on behalf of another organisation.

Owning an online marketplace

An online marketplace is a website that has been set up to allow non-UK organisations to sell their goods online. If you own an online marketplace, you may need to take action. If your organisation owns a website that sells goods from UK organisations only, this is not classed as an online marketplace.

Hiring or loaning out reusable packaging

If you hire or loan out reusable packaging, you may need to take action. For example, some organisations hire or loan out wooden pallets to other organisations for transporting goods. The wooden pallets are returned after use and loaned out again.

Supplying empty packaging

You may need to take action if you make and then supply empty packaging to a business that is not classed as a large organisation. For organisations that are not classed as large, both of the following apply: they have an annual turnover of less than £2 million; they handle or supply less than 50 tonnes of packaging a year.

Packaging definition

Packaging is any material that is used to cover or protect goods that are sold to consumers. It makes handling and delivering goods easier and safer. It includes anything that’s designed to be filled at the point of sale, such as a coffee cup. Packaging also makes goods look appealing and it may display a company’s logo or brand. ‘Goods’ could include raw materials or processed items.

What you may need to do

Under the new regulations, you may need to: collect and report data on the packaging you handle and supply; pay a waste management fee; buy packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet your recycling obligations; report information about where your packaging has been sold, hired, loaned, gifted or discarded – this is called ‘nation data’.

What you need to do depends on whether you’re classed as a ‘small’ or ‘large’ organisation. This is based on: your annual turnover; how much packaging you handle and supply each year.

Check if you’re a large or small organisation

You will be classed as a small organisation if: your annual turnover is between £1 million and £2 million and you’re responsible for handling and supplying more than 25 tonnes of empty packaging or packaged goods through the UK market; your annual turnover is over £1 million and you’re responsible for handling and supplying between 25 tonnes and 50 tonnes of empty packaging or packaged goods through the UK market.

You will be classed as a large organisation if both of the following apply: you have an annual turnover of £2 million or more; you’re responsible for handling and supplying more than 50 tonnes of empty packaging or packaged goods in the UK.

You should base your annual turnover on your most recent annual accounts. Your total weight is the amount of packaging handled or supplied through the UK market in a calendar year (January to December).

If you’re a small organisation

To comply with the regulations, you must: take steps to record data about all the empty packaging and packaged goods you handle and supply through the UK market from 1 January 2023; create an account and register your organisation from January 2024; pay an annual fee to the environmental regulator from 2024; report data about empty packaging and packaged goods you handled or supplied through the UK market throughout 2023. You’ll need to report your data between 1 January 2024 and 1 April 2024. If you miss the deadline, you may need to pay a penalty charge.

You may also need to report nation data if you’re a large organisation. To comply with the regulations, you must: take steps to record data about the empty packaging and packaged goods you handle and supply in the UK from 1 January 2023; create an account and register your organisation from July 2023; pay a fee to the environmental regulator; buy PRNs or PERNs to meet your recycling obligations; report data about empty packaging and packaged goods you handled or supplied through the UK market.

You’ll need to report data every 6 months. For the period January to June 2023, report data between July 2023 and 1 October 2023. If you miss the deadline, you may need to pay a penalty charge.

For any packaging you handle and supply that is collected by local authorities from households or street bins, from April 2024 you must pay the scheme administrator: an administrative fee; a waste management fee; You may also need to report nation data.

PRNs and PERNs

A PRN (packaging waste recycling note) or PERN (packaging waste export recycling note) is a certificate proving that packaging waste has been recycled properly. You can buy PRNs and PERNs from accredited re-processors. Re-processors are responsible for recycling packaging waste. By buying PRNs and PERNs you work towards meeting your recycling target.

If you’re a parent company, group or subsidiary there are different ways you can comply with EPR for packaging. You can register: as a whole group (in this instance, the parent group complies with EPR for packaging on behalf of every subsidiary within the group); as individual subsidiaries (in this instance, the subsidiaries that meet the turnover and tonnage requirements comply with EPR for packaging independently); as a parent company for part of the group (this is where the parent company registers to comply with EPR for packaging on behalf of some, but not all of its subsidiaries).

You should register as a parent company for part of the group if some of your subsidiaries do not meet the turnover and tonnage requirements in their own right, but do meet the requirements when combined. In this instance, the parent company will comply with EPR for packaging on behalf of the combined subsidiaries.

Check if you need to report nation data

Nation data is information about which country in the UK your packaging has been sold, hired, loaned, gifted or discarded in. If your organisation must act under EPR, you’ll need to report nation data if you also do any of the following: supply filled or empty packaging directly to consumers in the UK; supply empty packaging to UK organisations that are not legally obligated under the regulations; hire or loan out reusable packaging; own an online marketplace where other organisations sell their empty packaging and packaged goods to UK consumers; import packaging to the UK that you discard without selling or exporting it.

You must report your nation data for the 2023 calendar year by 1 December 2024. If you miss the deadline, you may need to pay a penalty charge.

Collecting and reporting your packaging data

Your organisation should start preparing now to capture your packaging data. Your data submission must include the information about the: packaging activity – this is how you put the packaging on the market; packaging material and weight; packaging type – primary, secondary, shipment or transit; waste type.

Find out more about how to collect your packaging data

Getting help from a third party: Compliance schemes are third parties that help organisations meet the EPR for packaging requirements. Compliance schemes can: pay your registration fees; buy PRNs or PERNs to meet your recycling obligations; report your packaging data. A compliance scheme cannot pay your waste management fee. If you choose to work with a compliance scheme, you should make sure they appear on the compliance scheme public register.

How to collect your packaging data for extended producer responsibility

Packaging waste: producer responsibilities

Check if your material is waste, is a by-product or meets ‘end of waste’ status.

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