EPR has recently been launched in the UK and at Cater For You we are being asked many questions by our suppliers and customer so we’ve asked Beyondly, a leading consultancy and compliance firm to create the FAQ’s below for those wishing to find out more.
Author: Michael Jennings, Packaging Compliance & Policy Account Manager at Beyondly Global Limited
What is Packaging EPR?
Packaging Extended Producer Responsibility (pEPR) is an environmental policy approach through which a producer’s responsibility for a product is extended to the post-use stage, incentivising the design of products so they are easier to be reused, dismantled, and recycled at ‘end of life’.
Which organisations are obligated by packaging EPR?
Producers are obligated under pEPR if they meet certain tonnage and turnover thresholds either on their own, or as part of a group of companies where applicable
If a producer handles over 25 tonnes of packaging and has a turnover of over £1m they would be obligated as a small producer to report their packaging annually by April.
If a producer handles over 50 tonnes of packaging and has a turnover of over £2m they would be obligated as a large producer to report their packaging handled biannually by 1 Oct for their January -June data, and by 1 April for their July-December data. As a large producer, fees (PRNs and potentially EPR Disposal Fees) would also be raised on the packaging they have placed on the market for that period.
How do I achieve packaging EPR compliance?
To achieve compliance, a producer must complete a submission by the required deadline (annually for small producers, bi-annually for large producers) and to pay any EPR Disposal Fees, if required, on packaging destined for the household waste stream, or deemed to end up in a public bin. They will also be required to procure PRNs (Packaging Recovery Notes) to cover their recycling obligations based on their submission.
I already pay for my commercial waste to be collected. Why do I need to pay more fees?
Collection of commercial waste from a business premises is generally paid for by businesses and therefore, isn’t covered by any of the fees under pEPR.
There are two fees under pEPR which both relate to different stages of the waste packaging journey.
The new EPR Disposal Fees cover the cost to Local Authorities of collecting and sorting packaging waste from households. This cost was previously borne by local authorities and the taxpayer, but will now move to the producer responsible for placing that packaging on the market.
PRNs relate to the cost of reprocessing packaging waste back into its raw form (recycling). For every tonne of packaging a reprocessor recycles, they can raise a PRN (packaging recovery note). These can then be sold to producers to meet their recycling obligations laid out in the regulations. As a compliance scheme, Beyondly takes on the responsibility of procuring PRNs for its members, using its purchasing power to help secure optimum prices for its members.
My turnover last year was £950,000. Can I ignore EPR?
Even if you turned over half that amount, ignoring pEPR is not recommended, as it’s bound to affect you in some way, even if you aren’t obligated at the moment.
As your turnover is less than £1m, you might not be obligated yet, but with the amount of data that will needed to be gathered for completing a pEPR submission when you become obligated, it would be best to start looking at what you need to gather, how to present the relevant data, and aligning your systems now.
Missing a deadline does have potential consequences, so please ensure to plan well in advance to allow sufficient time for communicating up and down the supply chain to gather the data you need. If you are unsure, please speak to a compliance scheme, such as Beyondly, who will be happy to advise on the next steps you need to take.
I’ve no idea how many tonnes of packaging I handle over the year. Can I just guess? Who will check?
There are seven main criteria you’ll need to check against to see how much packaging you have handled in a year.
- Supplied under your Brand: This is any packaging on which your brand, name, or trademark appear.
- Packed or Filled: This is any unbranded packaging you are filling in the UK, or branded packaging you are filling for a brand owner who is below the large producer threshold.
- Imported: You are obligated for all packaging you import, unless you are importing branded packaging on behalf of a large brand owner. This includes any filled or empty packaging that you are importing and discarding of.
- Supplied as Empty: If you are the importer or manufacturer of empty packaging, you will pick up the obligation for it unless you can evidence that it will be filled by a large producer, or large brand owner.
- If you operate an online ‘marketplace’ that lets overseas companies or individuals to sell goods or empty packaging to customers in the UK, you would be obligated under the activity ‘Supplied via Online Marketplace’.
- If you hire or loan out packaging that you own, you would be obligated for this packaging on its first use under the activity ‘Hired or Loaned’.
- Lastly, if you supply filled packaging to the end user of that packaging but don’t fulfil any of the activities 1-6, then you would need to record this against your packaging handled threshold. This wouldn’t be in your annual/bi-annual submissions but will be needed in the future for ‘Nation of Sale’ submissions.
I missed the April 1 deadline to register. Will I be penalised? Is it better to fess up now or just keep my head down?
If you miss either of the submission deadlines (1 October, or 1 April every year) then you could be liable for a late fee of £330 per missed submission. In this instance you are best off contacting a compliance scheme and getting the ball rolling to complete your submission as quickly as you can to avoid any extra fees or civil sanctions.
If you miss the submission period completely (31 December in the year following packaging being placed on the market) then you could go through an Enforcement Undertaking procedure and pay a fee to rectify missing historical submissions.
What kind of fees are we talking about? And when do they have to be paid?
To fulfil your obligations after completing your submissions, PRNs and EPR Disposal fees for large producers will need to be paid. PRNs are publicly traded and if you are signed up with a compliance scheme, they will purchase these on your behalf. EPR Disposal Fees are raised directly by the Government and can be paid in quarterly instalments following being invoiced in July (or October 2025 for the first year of fees).
Many of my suppliers have already added an EPR levy to the prices they charge me. Why do I have to pay my own EPR fees on top of that? Isn’t the government collecting money twice for the same product?
Under the new pEPR regulations, the obligation for packaging will only fall to a single producer. If you believe that the obligation should fall to you, but you are being charged by a supplier, it is worth speaking to them to make sure that the correct producer is picking up the obligation. NB: You cannot choose who picks up the obligation for packaging between you, the obligated party will be the producer who completes one of the activities 1 – 6 above.
It is worth noting that if you are a small producer and are buying empty packaging from the Importer or Manufacturer of that packaging, they would be obligated for the packaging under the activity ‘Supplied as Empty’ and would have to pay related fees even if you are reporting the packaging in your submission too, as either pack/filler or brand owner. This is because, as a small producer, you would be completing your submissions but wouldn’t be paying fees for that packaging.
Is it better to handle all the admin myself or call in the experts? How much will that cost me if I do?
It is worth weighing up the cost to you of gathering and reporting the data yourselves, vs working with a government approved compliance scheme to gather and/or report your data for you. Costs vary significantly between compliance schemes and are also dependent on your business size and requirements.
For example, Beyondly is a packaging EPR compliance scheme and advises producers on the gathering, organisation and reporting of their data. We will then purchase PRNs on their behalf to meet their recycling obligations.
Beyondly also provides a range of additional data management services to complement the compliance scheme offering, including data gathering and contacting producers’ suppliers, through to data submission support and data insights to furnish producers with the granular information on what packaging is attracting the most fees and where changes can be made.
If you are interested in attaining pricing or would like a chat about the next steps you need to take, please contact [email protected] or call 01756 794 951
What’s the best way to maintain records and keep on top of my EPR admin going forward?
Data can be stored in any way you want in alignment with your company’s internal processes, however, it’s vital to ensure your records are clear and accurate with a methodology on how, why, and where you have attained your data, along with storage for seven years.
With Beyondly, your account manager will be able to help and advise on how to gather the data your need, as well being able to help you with data presentation; not only to ensure compliance now, but also to help you futureproof in line with the development of pEPR over the coming years.
It’s also worth talking to customers and suppliers in your supply chain to make sure that you are all on the same page as to the data you are capturing and sharing. This is to ensure efficient cross supply chain collaboration as greater data requirements are introduced over the coming years.
Are you a Large Producer under Packaging EPR? Visit the Beyondly website to read more and stay updated on all packaging EPR related policy developments.
Notes to editors
For media enquiries please contact the marketing team – [email protected]
- Beyondly Global Limited is a B Corp certified, government approved producer compliance scheme and sustainability consultancy. Beyondly help businesses become more confident about their environmental choices; from compliance obligations, contributing to a circular economy, and going beyond net zero.
- The business’ purpose is to lead, inspire and educate to positively impact society and the environment. The company vision is to create a better, fairer, sustainable world for all.
- More information about Beyondly and their full-service offering is available on their website – www.beyond.ly
