Introduction
Packaging Extended Producer Responsibility, or EPR for short, is a regulatory mechanism used by government to ensure that producers pay the full cost of collecting and recycling the packaging that they place on the market, at the end of its life.
The new measures for EPR are more complex and for some will be significantly more expensive than the UK packaging producer responsibility regulations they replace, that have been in place since 1997.
What is the purpose of EPR?
EPR in general is an environmental policy tool used worldwide to embed the 'polluter pays principle' and encourage movement towards a circular economy, where materials are more easily recovered, recycled and reused.
Packaging EPR is intended to incentivise obligated producers to use less packaging and more easily recyclable materials, reducing the amount of hard-to-recycle packaging placed on the market. This is done by making them responsible for funding the collection and recycling of their packaging when it becomes waste, with hard-to-recycle materials attracting higher EPR costs.
It also ensures that funding is raised to help improve recycling performance and infrastructure.
When is it taking place?
EPR for packaging in the UK started to be phased in from 1 January 2023 and is expected to be fully implemented by 2027. You must check now if your organisation is impacted so you can start taking action.
Our article Timelines of packaging EPR implementation explain how the new measures are being phased in.
Important to know
To date, most details have been confirmed by government about how packaging EPR will function, to help organisations prepare. All our guidance highlights any gaps in the detail that you need to be aware of.
Am I impacted?
Packaging EPR measures impact all UK organisations that handle or supply packaging, and it is a legal requirement to comply with them.
You may have significant actions to take from 1 January 2023, including data collection, data reporting and financial obligations. Your actions depend on whether you meet the packaging EPR threshold criteria set by government, and if you are classed as a small or large organisation. We explain how to check this in the next article Identify if your organisation is impacted by packaging EPR.
All organisations - including those under the EPR threshold - will need to eventually comply with mandatory labelling requirements to inform consumers if their packaging can be recycled. However, in September 2024 government announced they had removed this provision from the regulations, but as a temporary position. It is likely some form of mandatory labelling be enforced under EPR, but it remains to be seen when this will be the case.
gov.uk EPR obligation checker
At the end of 2022 government launched an online tool to check if you have any packaging EPR data obligations. To visit the gov.uk checker please click here.
What will I have to do?
Obligated organisations have various required actions under packaging EPR. Depending on your organisation size and activities, these may include:
Paying scheme administrator fees
Labelling your packaging to inform consumers about its recyclability
Note that these EPR measures should not be confused with the Plastic Packaging Tax. The tax is a completely separate mechanism that was implemented by HMRC in 2022. If you use plastic packaging, you will also need to comply with the Plastic Packaging Tax in addition to any packaging EPR obligations.
Next steps
See our next article to Identify if your organisation is impacted by packaging EPR.
External references
gov.uk EPR obligation checker tool
Read the official packaging EPR guidance on gov.uk
Page updates
3 October 2024 - we updated the 'Am I impacted?' section regarding mandatory labelling, as it is now unknown when this will come into force.
25 April 2024 - we updated the 'Am I impacted?' section with the new date for mandatory labelling of 2027.
Ben Luger
Marketing Project Specialist
Ben helps drive marketing communications and projects for Ecosurety, including project managing the launch of the Ecosurety Exploration Fund and website content development.
