Packaging Extended Producer Responsibility – Monthly Member Update

Packaging Extended Producer Responsibility – Monthly Member Update

The UK government is introducing new extended producer responsibility (EPR) for packaging regulations for UK organisations who supply or import packaging into the UK. The requirements under these regulations are being phased in from 2024 onwards.

To support members with the implementation of the new requirements, and to keep members up to date with the latest announcements, we will publishing a monthly member update. This will provide updates on: regulations and governance, data reporting, guidance and engagement, and recyclability labelling.

With the support of our environmental partners Beyondly, we will keep the BTHA packaging EPR member guidance up to date in line with any changes. Members can view and download the BTHA guidance.

Regulations and governance:

  • The Scheme Administrator for packaging EPR is beginning to assemble and take shape. Dr Margaret Bates has been appointed as the Head of Scheme Administrator, with an interim steering group made up of producer, waste management, local authority, and government representatives, to steer the set up of the Scheme Administrator. There have also been three additional advisory bodies proposed and are undergoing set up, to allow wider industry to advise on the Scheme Administrator. They are: a Producer Responsibility Organisation (PRO), a Local Authority advisory organisation, and a communications advisory organisation. The steering group and the three advisory bodies will advise Dr Margaret Bates & Defra on setting up the Scheme Administrator.

Data reporting:

  • Packaging data is due to be submitted to the regulator (the environmental agencies) under The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 for the 7th April 2024 if you are a direct registrant (if you do not use a compliance scheme) or for the 15th April 2024 via your compliance schemes (if you are registered with one). If you use a compliance scheme, the scheme will request your packaging data ahead of this date (15th April) so it can verify your details and data. Deadlines can vary from scheme to scheme.
  • Packaging EPR data is due to be submitted to the regulator under The Packaging Waste (Data Reporting) (England) Regulations 2023 (as amended) (or the parallel Wales/Scotland/Northern Ireland regulations if that is where your company is based).
    • 1 October 2023: Submit January – June 2023 placed on market packaging data
    • 1 April 2024: Submit July – December 2023 placed on market packaging data
    • 31 May 2024: A Regulatory Position Statement published in September 2023 states that producers that miss the above pEPR deadlines for 2023 data, can submit until 31 May 2024 without enforcement action taken if needed. The regulators still encourage producers to meet the above deadlines if possible. The RPS is only in place for 2023 pEPR placed on market data.
    • Again, if you are a member of a compliance scheme it will request your packaging placed on market data earlier than these deadlines, so it can verify your details and data.
  • You should also begin to collect packaging placed on market data for 2024, to be submitted later in the year.

Guidance and engagement:

  • Sign up to Defra’s Resource & Waste newsletter, in which they notify us of any engagements with industry. Sign up here. Defra run monthly Business Readiness Forums which are aimed at sharing information and engaging in discussions/questions with producers. You can register for them and find the dates within the newsletter. Defra also run ad hoc webinars and other engagement sessions which are outlined in the newsletter.
    • Dates of Business Readiness Forums (and other Resources & Waste Forums) in 2024 and links to register can be found here.

Recyclability labelling:

  • Government is still considering the dates by which obligated producers must apply recyclability labels to primary and shipment packaging being placed on the UK market. They may be delayed in line with the delay of bringing the ‘Main Packaging EPR Regulations’ into force, which contain the provisions for recyclability labelling. These Regulations were delayed coming into force by a year; they are now due to come into force in late 2024. The current dates for recyclability labelling are:
    • 31 March 2026: all primary and shipment packaging, except plastic films and flexibles, must be labelled.
    • 31 March 2027: for all primary and shipment packaging inclusive of plastic films and flexibles, must be labelled.
  • The BTHA is creating a packaging EPR recyclability labelling guidance document for members, which will be published soon.

If members have any questions on the new requirements, please get in contact with kerri@btha.co.uk

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