Introduction
Extended Producer Responsibility (EPR) measures for packaging came into force on 1 January 2023. This is when most organisations impacted by it will have to start taking action, particularly in terms of registering or collecting data about their packaging.
Further EPR measures will be implemented over time and the following article and video cover the key dates you need to understand, especially in terms of any resulting actions you must take.
Watch explainer video
Governance timeline
A Scheme Administrator will be fully operational from 2024. They will manage all packaging EPR data submissions, waste management fees and the subsequent flow of funding from large organisations to local authorities. The Environmental Regulator, for example the Environment Agency in England, will continue to manage Packaging waste Recycling Note (PRN) obligations, as they have historically.
From 2024 the Scheme Administrator will start to distribute the waste management fees paid by large organisations to local authorities, to cover the cost of collecting and sorting packaging from households and street bins.
Mandatory take-back of disposable cups will begin in 2024 for large sellers (with ten or more employees) but the introduction of refill and reuse EPR measures in 2025 are yet to be confirmed by government.
Mandatory labelling on packaging to specify if it is recyclable or not will come into force from 2026, and will include flexible plastics from 2027.
Small organisation required actions timeline
Organisations classed as small under packaging EPR should start collecting data on the packaging they handle or supply from 1 January 2023, and then create an account and register from January 2024. From 2024 they must also submit their data between 1 January and 1 April. Data collected from 2024 will include a self-assessment of the recyclability of the packaging, the exact details of which are to be confirmed by government.
In 2026, mandatory labelling begins for all packaging to inform the end user if they should or should not recycle it. This will exclude film and flexible packaging, until 2027 when it is included.
If a small organisation meets the nation data criteria, that data must be reported separately, once a year starting from December 2024.
Read more to understand small organisation packaging EPR required actions.
Large organisation required actions timeline
In 2023, organisations classed as large under packaging EPR should start collecting data on the packaging they handle or supply from 1 January, create an account and register from July and start reporting their data bi-annually between 1 July and 1 October. Data collected from 2024 will include a self-assessment of the recyclability of the packaging, the exact details of which are to be confirmed by government.
In 2026, mandatory labelling begins for all packaging to inform the end user if they should or should not recycle it. This will exclude film and flexible packaging, until 2027 when it is included.
If a large organisation meets the nation data criteria, that data must be reported separately, once a year starting from December 2024.
Read more to understand large organisation packaging EPR required actions.
Statutory instrument impact on data collection and reporting
The statutory instrument that requires producers to collect packaging EPR data didn’t become law until 1 March 2023. If producers have recorded data from January they should submit it to ensure an accurate obligation. If you do not have data starting from January be aware that you are legally required to record data from 1 March 2023 and the scheme administrator will estimate data for the missing period. The statutory instrument covers England, Scotland and Northern Ireland.
The statutory instrument for Wales is expected to become law in mid-2023. Both small and large producers based in Wales are encouraged to comply with the data recording schedule detailed above but if that is not possible, they should start collecting data from the date the regulations come into force and submit it between 1 January and 1 April 2024.
Financial obligations timeline
An annual registration fee is payable to the environmental regulator, starting from July 2023 for large organisations and from 2024 for small organisations.
Large organisations must buy PRNs to cover their EPR obligation from the previous calendar year, starting from 2024 based on their 2023 data. Note that producers obligated under the old packaging compliance regulations will also need to purchase PRNs in 2023 to cover their 2022 obligations.
Large organisations must also pay a waste management fee to the Scheme Administrator from 2024, for packaging likely to end up as household waste. This is based on the previous calendar year data, payable quarterly in the following financial year. From 2025 the waste management fee will be fully modulated and based on recyclability self-assessment of the packaging.
Read more to understand your packaging EPR costs.
Next steps
If you have not yet already, Identify if your organisation is impacted by packaging EPR.
External references
Read the official packaging EPR guidance on gov.uk
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.
