Extended Producer Responsibility (EPR)

Extended Producer Responsibility (EPR) is a significant shift in policy, that holds producers responsible for the environmental impact of their products.

So what does that mean for the packaging industry?

Well, when it comes to packaging, it means producers are responsible for the collection, sorting and recycling of their packaging waste.

With new collection and reporting requirements related to packaging in the UK, it’s essential for organisations within these markets comply with the relevant data collection, reporting requirements and deadlines to avoid costly fines and levies.

In a broader sense, EPR is a powerful opportunity for producers to create a more circular and sustainable packaging system. But in order to do so, it’s imperative for businesses to understand the details and take proactive steps in ensuring they remain compliant and contribute to a better environmental impact.

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Who is Affected and What Needs to be Reported?

Extended Producer Responsibility (EPR) applies to any UK organisation (exc. charities) who:

  • Is an individual business, subsidiary or group.
  • Had an annual turnover of £1 million or more.
  • Handles over 25 tonnes of packaging annually.

This includes importers, manufacturers and retailers.

Packaging broadly covers any material used to protect or contain goods, even those intended to be filled at point-of-sale.

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Financial Responsibilities & Incentives

New EPR regulations mean that the producer is now responsible for the full cost of managing and recycling their packaging waste.

The cost is done through fees based on the Recyclability Assessment Methodology.

Using that model of fee calculation, EPR incentivises producers to focus and transitions on more sustainable and recyclable packaging.

Not only does that keep their costs low, it has a considerable environmental impact overall.

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Driving Changes in the Supply Chain

EPR isn’t just about holding producers financially responsible.

Extended Producer Responsibility (EPR) encourages greater transparency across the supply chain. Providing more information on packaging production, waste and treatment for both producers and consumers.

This transparency invites a more collaborative environment between producers, government and other stakeholders to achieve shared environmental goals.

EPR also pushes businesses towards adopting far more sustainable practices, moving towards a circular economy model – ultimately reducing waste and maximising resources.

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Compliance & Consequences

The most crucial part of Extended Producer Responsibility (EPR) is making sure you’re compliant.

Failure to comply with EPR regulation can result in significant financial penalties, including fines and levies and even criminal prosecution.

Environment Agencies are actively monitoring compliance efforts and have the power of enforcement against organisations that are failing to meet their obligations.

What are your EPR Packaging Obligations?

Our calculator enables you to estimate your business’s costs under packaging Extended Producer Responsibility (pEPR).

Enter your packaging obligations (your EPR obligation is the sum of all household and street bin packaging reported in half year 1 and half year 2, but remember to exclude aluminium and PET drinks containers) into the tool, in tonnes, and then click calculate for cost estimates based on the following three scenarios: lower, intermediate, and higher. Once you have submitted your contact details, you will see a range of potential costs based on the data provided.

The cost estimates will not include recycling evidence (PRN) fees.

Table 1 – Packaging EPR cost forecaster tool

Aluminium Fibre-based composites Paper Glass Plastic Steel Wood Other
Household obligation in tonnes

Please fill in the form below to see your answer

Summary of your EPR costs

Material Lower estimate total Intermediate estimate total Higher estimate total
Aluminum
Fibre-based composites
Paper
Glass
Plastic
Steel
Wood
Other
Total

The above forecasts are based on a range of estimated fees provided by Defra. Defra has advised not to use the high estimates and low estimates to forecast best- and worst-case scenarios, as it is likely that different materials will fall in different places on this spectrum

For relatively balanced or mixed obligations, we feel that the intermediate fee is a reasonable estimate to use.

For single material obligations, or heavily dominated material obligations, then it is possible that the high scenario could occur, so we suggest you consider the full range of fees in these instances.

When forecasting for 2025 compliance it is important to remember that producers will still be required to pay for Packaging Waste Recovery Notes (PRNs).


Reduce your pEPR costs with Smart Comply's expert services

Our suite of Packaging Analysis services assists businesses in achieving data accuracy and meeting packaging sustainability goals, which can lead to reduced packaging compliance costs.

We can help identify cost-saving opportunities, improve the sustainability of your packaging, and ensure your business is compliant. With packaging compliance costs rising, now is the time to act.

The EPR Basics…

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