The UK’s new packaging Extended Producer Responsibility (pEPR) Regulations mark a significant shift in how businesses contribute to packaging waste management.
With new cost structures and obligations depending on the type of packaging a business places on the market, it’s important to understand what different producers need to pay for and how compliance varies.
Below, we have broken down the key scenarios and financial responsibilities under the new system.
Large producers: Full EPR obligations
Large producers (those exceeding £2m turnover and handling more than 50 tonnes of packaging annually) must meet the full set of EPR obligations, including:
- Packaging waste management fees: Paying modulated fees based on the recyclability of their household packaging through the new Recycling Assessment Methodology (RAM), which affects producers of household packaging only. Note that year 1 costs for 2024 placed on the market material will only incur base pEPR fees, with the RAM commencing from 2025 onwards.
- Nation-of-sale data reporting: Tracking where packaging is sold across the UK to ensure fair cost allocation between different nations.
- Packaging Waste Recovery Notes (PRNs) or Packaging Export Recovery Notes (PERNs): While EPR replaces some previous compliance costs, large producers still need to purchase PRNs/PERNs to contribute to packaging waste recycling.
- Reporting packaging placed on the market bi-annually and registering with the Environment Agency.
Producers of household vs. non-household (Commercial & Industrial) packaging
The cost burden varies depending on whether a producer supplies household or non-household packaging:
- Household packaging producers: Subject to full pEPR fees for 2024 sales onwards, including the Recycling Assessment Methodology for 2025 sales onwards, which determines modulated fees based on recyclability.
- Non-Household packaging producers: While not subject to pEPR / RAM fees, they must still contribute through PRNs/PERNs and report packaging data under the new regulations.
Small producers: Data collection but no direct fees (yet)
Small producers (£1m+ turnover and between 25-50 tonnes of packaging annually) are required to collect and report packaging data but are not yet obligated to pay pEPR fees. However, they must still monitor changes, as future updates may introduce additional financial responsibilities.
Importers and online marketplaces
Businesses importing packaged goods or facilitating sales via online marketplaces face unique obligations:
- Importers: Responsible for compliance if the packaging is disposed of in the UK, with fees similar to large producers.
- Online marketplaces: May be classified as obligated producers if they facilitate transactions where sellers are not UK-based, ensuring that foreign businesses selling to UK consumers contribute to EPR costs.
Retailers and own-brand producers
Supermarkets and retailers selling own-brand products are responsible for compliance, similar to large producers. They must account for all own-brand packaging under EPR, contributing to waste management fees and PRN/PERN purchases.
How Valpak can help
Navigating these new obligations can be complex, but with our expertise we ensure your business remains compliant and cost-efficient. We offer:
Understanding your obligations and preparing for the financial impact of pEPR is key to compliance. Contact us today on 03450 682 572 to ensure your business is ready to meet the new requirements efficiently and effectively.
