Ecoveritas is an environmental compliance data specialist that provides a range of tools and expertise to brands, retailers, and supply chains to efficiently minimise the environmental impact of their packaging.

To meet the complex challenges of managing environmental compliance reporting, Ecoveritas offers a unique combination of consulting, data and software that helps companies around the globe take the next step in their sustainability journey.

Our team takes a fresh approach to the environmental compliance market by adding years of supply chain and technical development expertise to an experienced environmental data team to provide SaaS-based services.

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Defra have confirmed it is delaying a number of important aspects of the EPR for packaging reform programme which further complicates reporting and compliance over the next 12 months.

Links to the announcements are below:

https://www.gov.uk/government/news/update-on-packaging-reforms-to-help-drive-down-inflation

https://createsend.com/t/t-5852797C941365992540EF23F30FEDED

UK EPR fees have been delayed:

Defra is delaying the responsibility to pay new waste management fees, commonly referred to as ‘EPR fees’. The fees are intended to cover the net costs of local authority household waste management services, with producers previously due to start paying them in October 2024 to cover their obligations for the packaging they placed on the market across 2023. The introduction of these fees has been postponed by 12 months, so now producers will start paying EPR fees in October 2025 for packaging placed on the market across 2024.

UK EPR reporting is not delayed:

Obligations to report packaging data in the new way, based on new producer categories (i.e. brand owner, importer, online marketplace, etc.) and the principle of single-party responsibility, passed into law in March 2023. Despite delaying EPR fees, Defra has not altered these data reporting laws. As such, large producers are still required to collect and report their packaging data for EPR from 16 August, and they have until 1 October to complete that report.

Producers still have to fund the recycling of packaging next year and therefore dual reporting is required: EPR fees were due to be introduced as part of a new statutory instrument that would replace the Packaging Waste Producer Responsibility Regulations 2007; however, the 2007 regulations will now remain in place for an additional year. This means that producers will have two pieces of legislation to comply with for 2024:

The current Packaging Waste Regulations will remain in force for 2024 – they will continue to provide the basis for packaging compliance by all obligated companies.
The new (2023) Packaging Waste (Data Reporting) Regulations will also remain in force – they will enable current and new producers to collect and report data – this will be the basis for Packaging EPR in 2025 and beyond.

What does this mean for 2024 packaging compliance?

Costs in 2024 will be on the same basis as they are in the current system (environment agency registration + PRN costs + your compliance scheme membership fees). The significant additional costs for collection of packaging waste from households will not be passed on to producers until 2025.

What does this mean for packaging data reporting?

For packaging handled / placed on the UK market in 2023, Producers will need to collect and report data under two systems!

1. Packaging handled - as required by the current Packaging Waste Regulations

Report by April 2024
This will form the basis for PRN requirements for 2024 packaging compliance

2. Packaging placed on the market – as required by the various national Packaging Waste (Data Reporting) Regulations

Report H1 2023 by 1st October 2023
Report H2 2023 by 1st April 2024
Report nation of sale by end of December 2024 (NB this remains to be confirmed)

Extended Producer Responsibility (EPR) is a new UK legislation that will replace the current Packaging Waste Regulations with a phased implementation from 2023. It is an environmental policy that requires producers to pay the full costs of dealing with the waste they produce from when it is placed onto the market, through to the end of its life. Please get in touch with Ecoveritas to discuss how the new legislation will impact your business.

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