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Understanding Extended Producer Responsibility For Packaging

  • 4th November 2024
  • 5 min read

In 2023 the Packaging Regulations in the UK were reformed, where Extended Producer Responsibility is now in its place. However, this won’t come into effect until 2025. This is already in effect with businesses needing to record their data and make the 2024 H1 submission.  Charges will not come into effect until 2025 based on the 2024 submission data. This change forces businesses to bear the Full Net Cost of packaging disposal at end-of-life.. 

In this blog we’ll explore everything you need to know about Extended Producer Responsibility and how it will affect your packaging strategy.  

What is EPR? 

Extended Producer Responsibility (EPR) is a mandatory environmental policy across the UK that ensures companies are fully accountable for the impact the following product categories have on the environment:

  • Packaging.
  • Batteries.
  • Waste Electrical and Electronic Equipment (WEEE).

Extended Producer Responsibility (EPR) has been implemented to ensure producers take responsibility for their packaging throughout the entire lifecycle, including the post-consumer stage. This will help offset the cost of recycling their material in the UK waste stream.

What are the aims of EPR?

  • To ensure businesses take accountability for their packaging from conception, right through to the end of life. 
  • To encourage a review of the current packaging used and potentially change the materials and/or quantity used.
  • To increase packaging recyclability and reusability.

How will Extended Producer Responsibility affect packaging costs?

The current producer responsibility system shares the costs throughout the supply chain. These costs are split into the following percentages:

  • Manufacturers of packaging materials pay 6%.
  • Businesses that convert raw materials into packaging pay 9%.
  • Businesses that pack/fill the packaging pay 37%.
  • Businesses that sell the filled packaging pay 48%.

Under EPR, one business will have 100% of the responsibility for complying and paying for the costs under Extended Producer Responsibility regulations. 

Extended producer responsibility regulations

Small businesses must comply with Extended Responsibility Regulations if:

  • They have an annual turnover of over £1 million.
  • They have generated more than 25 tonnes of packaging waste in the UK market in the previous calendar year.

Large businesses must comply with EPR regulations if they have an annual turnover above £2 million and generated over 50 tonnes of packaging waste in the previous year.

If you don’t meet the above points you don’t need to register, but you will need to monitor your packaging usage and annual turn over to ensure you comply with these regulations each year. 

Our packaging consultants at Titan Packaging can help you collect data across your packaging lifecycle, allowing you to stay compliant with EPR regulations and identify areas of improvement throughout your packaging operations. This will help improve overall efficiency, save money and decrease returns rates as your packaging will protect your products.

For further information and guidance regarding the new Extended Producer Responsibility regulations, get in touch with us today.

Extended producer responsibility legislation

EPR legislation mandates that product and packaging manufacturers, importers, and brand owners take responsibility for minimising their products' and packaging's environmental impacts throughout their lifecycle. This means businesses must contribute to all costs associated with collecting, recovering, and disposing of their materials. Additionally, they must invest in consumer campaigns to educate consumers about proper recycling practices.

Extended Producer Responsibility key points

There are a few key points businesses should be aware of regarding EPR, including:

  • As of October 2025 companies will have a greater responsibility for household packaging waste.
  • Businesses will need to collect and report additional data regarding packaging types and recyclability every six months. This has been in effect since 2023.
  • For organisations using hard or costly materials to recycle they’re likely to see an increase in compliance costs due to the introduction of eco-modulation of EPR fees as of 2026. 
  • A separate reporting obligation will be required for packaging supplied by the UK nation.
  • A binary recyclable label must be displayed on packaging clearly stating whether the packaging should or shouldn’t be recycled. This will come into effect as of April 1st 2027.

What is eco-modulation?

Eco-modulation offers rewards and penalties for how environmentally friendly a company’s products are. It can be applied to packaging, batteries and Waste Electrical and Electronic Equipment (WEEE).

How does eco-modulation work?

  • Eco-modulation fees are adjusted, with some types of packaging having higher fees than others. For example PVC packaging might have a higher price than plastic packaging.
  • Reimbursements may be distributed if producers make desirable choices.
  • When undesired choices are made, penalties may be given out.

At Titan we offer an Extended Producer Responsibility consultation where we can help you ensure your packaging protects the planet and that your operations comply with EPR regulations. Get in touch with us today to see how we can help. 

 

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Written by: Anna Punch Sales Director

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