Introduction
Getting to grips with packaging EPR is a complex task and just knowing where to start can be confusing. This article explains our recommendations for the actions that you should be taking now.
1. Identify your required actions under packaging EPR
If you haven’t done so already, Identify if your organisation is impacted by packaging EPR and Identify if your organisation is classed as small or large.
Depending on how your organisation size is classed, you can then understand either the Required actions for small organisations or the Required actions for large organisations. These requirements include enrolling on the Reporting Packaging Data gov.uk portal, data reporting and financial requirements.
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.
2. Understand the financial impacts of EPR on your organisation
If you are classed as a large organisation under packaging EPR, it is possible you could experience a significant increase in your financial obligations, compared to the previous packaging regulations. It is important that you know what these are, as explained in our article Understand your packaging EPR costs. This article also contains government’s illustrative base fees, to further help you estimate costs.
It is not possible to know your exact EPR costs in advance due to so many variables and unknowns, including confirmation of waste management fees and their modulation by government, and future PRN market performance. Given the scale of the potential increase in costs however, it is advisable to inform the senior leadership of your organisation with an estimation of your EPR costs based on the existing data you do have. This will help your organisation understand and appreciate the impact that packaging EPR will have on it, and hopefully inform strategic decisions that could help you get prepared and start to reduce your liabilities.
Ecosurety members on our Advanced or Premium membership plans can access our EPR cost modelling analytics which will give you a good indication of your costs for budgeting purposes, based on your most recent data.
3. Understand your data reporting requirements
Both small and large organisations have significant data collection and reporting requirements under packaging EPR, with increased complexity and frequency compared to the previous regulations. You must collect this data for all the packaging you handle or supply from 1 January 2023. The size of your organisation will determine when you must report it (read this article to identify if you are a small or large organisation).
It is critical that you understand what data you need to be collecting - our article Understand your packaging EPR data requirements explains what you need to know.
We have also published guidance on how Ecosurety members need to complete their EPR data submission, which will vary depending on the data submission support level you are on.
4. Get in control of your data
You need to ensure you can accurately complete the data recording and collection requirements by the specified deadlines, or risk a penalty charge.
Having this data to hand also means you can leverage it to inform any strategic decisions you make to improve your packaging and possibly reduce your EPR liabilities and environmental impact.
Request a Data Health Assessment. It is important to identify any weak points or gaps in your existing data that may prevent you from accurately reporting your data on time. Make sure you know where your biggest challenges are by identifying the areas that you have missing, incomplete or inconsistent data for. Only then can you efficiently and systematically improve your data. Our team can support you on this, contact us to find out more.
Establish processes to gather data internally and externally. Gathering the required data in the first place from your supply chains and internal departments may well be your biggest ongoing challenge. Get processes set up to ensure you are efficiently requesting the right data, at the right time from the right sources. Contact your data sources as soon as possible so they understand what you need from them and by when. Again, our team can help you with this.
We have further knowledge resources on data best practices to help you optimise how you collect, manage and report your data - you can browse them here.
Next steps
All of the above really describes the very beginning of your EPR journey, but they represent very important first steps that you should be taking now.
Make sure you also understand our Five steps to build your packaging EPR strategy and how to improve your packaging and reduce EPR costs.
External references
gov.uk EPR obligation checker tool
Read the official packaging EPR guidance on gov.uk
Read more about the illustrative base fees on gov.uk
Page updates
21 August 2024 - We added information about the illustrative base fees released by government.
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.
