What is Extended Producer Responsibility?

Over the past few decades, we’ve seen more and more of the UK government’s focus on circular initiatives when it comes to waste management. And while we’ve still got a fair way to go before the loop closes, it’s certainly encouraging to see the introduction of further legislation that protects our climate, drives green growth, reduces unnecessary waste and, most importantly, promotes resource efficiency.

The Extended Producer Responsibility (EPR) is one such piece of legislation that has the potential to alter the landscape of the packaging industry. But what exactly is the Extended Producer Responsibility and how might it affect your business?

Let’s take a look in more detail below.

Also known as Packaging Extended Producer Responsibility (pERP), Extended Producer Responsibility (EPR) is a circular economy initiative that aims to reduce unnecessary waste and keep packaging materials in use for longer. Once EPR is introduced, producers will be fully responsible, both financially and physically, for collecting and treating packaging once it becomes waste.

The idea of producers (i.e. individuals, businesses or organisations who produce waste) being liable for handling post-consumer waste isn’t anything new. In fact, the producer responsibility system first came into effect in UK law back in 1997 as the Producer Responsibility Obligations. Their aim was to:

• Reduce landfill waste
• Promote sustainability
• Making packaging producers responsible for recycling and recovery

For businesses to fulfil responsibilities, they had to meet recycling targets by purchasing Packaging Recovery Notes (PRNs) from accredited recyclers. This allowed businesses to pay a proportion of the cost of recycling packaging.

However, while the recycling rate of UK packaging waste has increased over the decades, the funds generated by PRNs covered only 7% of the actual cost of managing post-consumer packaging waste.

Inspired by other European countries, the UK government sought to reform the regulations in 2019, so that producers would be fully financially responsible for the packaging waste they place on the market.

The EPR was launched a few years later, with businesses required to start recording data about their packaging usage in January 2023. Starting from July 2023, eligible organisations had to register with Defra (Department for Environment Food and Rural Affairs) in order to submit their data.

Additionally, starting from April 2026, producers will be required to use clearer and more consistent labelling regarding how recyclable their packaging is. This is of vital importance; not all plastic packaging that makes it onto our shelves can be recycled.

Also of note: starting in the 2026-2027 financial year, the fees businesses have to pay will be adjusted based on recyclability. So any packaging that’s harder to recycle, for instance, will end up incurring higher costs.

Not every business has to adhere to Extended Producer Responsibility legislation. Businesses which have a turnover of less than £1 million and place less than 25 tonnes of packaging onto the UK market are exempt from the regulations.

Those who must comply with the ERP can be divided into two main categories: small producers and large producers.

Small producers

Small producers are businesses which meet either of the following criteria:

• Its annual turnover is between £1 million and £2 million AND it’s responsible for supplying or importing more than 25 tonnes of packaging in the UK
• Its annual turnover is over £1 million AND it’s responsible for supplying or importing between 25 tonnes and 50 tonnes of packaging in the UK

Large producers

Large producers, meanwhile, are businesses that meet both of the following criteria:

• Your annual turnover is £2 million or more (based on the latest audited accounts)
• You supply or import more than 50 tonnes of packaging or packaged goods in the UK

Whether you’re a small or large producer, you’re expected to do the following in line with Extended Producer Responsibility regulations:

1) Register on the Report Packaging Data online service, which can be done via a compliance scheme. This will give you an organisation ID, and is mandatory for EPR compliance.

2) Collect accurate data on the amount, material and type of packaging that they supply or import.

3) Report the collected packaging data. Small producers must do this annually, while large producers must report their data every 6 months.

4) Pay the necessary fees based on their collected data.

We’ve looked at the broad strokes of what producers must to do to comply, but like anything in business, a strong strategy makes can help make the process smoother and effective.

Here’s what we’d recommend doing…

Review your current packaging materials

Auditing your current packaging is a good place to start. If nothing else, you’ll be making sure that you know for sure what can and can’t be recycled. It’ll also help you set targets for recycling and disposal – and what systems, processes and resource you’ll need to help you achieve them.

Use this time to decide whether you can make some more sustainable packaging choices too. Since fees are based on how much pollution your product generates, opting for more sustainable, recyclable-ready packaging can save you more money in the long term.

Create an audit trail

The data collection involved with EPR compliance might mean working with suppliers to provide more details on the packaging they produce. Transparency is essential here, as any data collection errors slow down the process and create unnecessary admin.

Workflow and reporting tools not only make the process more efficient, but the audit trail they create provides clearer, more detailed records; version-controlled documentation and timestamped logs, all of which improve accountability, accuracy and retrievability when requests arrive.

Make sure teams are on the same page

If your packaging operations involves a lot of different teams, then mis-alignment could easily become an issue. This can lead to inconsistencies in product specifications, labels and sustainability claims. In turn, incorrect packaging could be misreported, which puts compliance – and your own brand’s reputation – in a precarious position.

Using software to create a single source of information each team can work from, and hold regular cross-team meetings and catch ups can help strengthen harmony amongst your packaging, artwork and compliance teams. When teams are on the same page, you’ll keep errors to a minimum and be able to boost efficiency.

Ultimately, businesses can be hit with financial penalties for failing to comply. It’s vital that you avoid these fines by maintaining processes and approaches that result in total compliance.

Although the UK government has announced that the EPR will be implemented in a phased manner from 2024, as opposed to 2023, it’s important to get your business prepared before it’s too late.

To help reduce the cost of handling packaging, it’s wise to invest in mono-material packaging. Mono-material packaging is much cheaper to recycle, as it’s composed of just one single fibre or material. This means that it requires less energy to recycle packaging, helping you cut back on costs.

We also specialise in designing 100% recyclable-ready packaging. We use mono polymer technology to design and construct mono-material films from a single polymer resin. Our products are also fully compliant in accordance with storage and distribution guidelines, quality compliance and environmental legislation for your peace of mind.

Our range of recyclable-ready and compostable products offer a variety solutions to help you meet your recycling goals, too. And with our expertise, we’ll support and advise you on the right product choices, based on the industry you’re in and what you want to achieve.

Don’t forget to check out the videos at our resources page for more EPR-related information.

Now that you’re more up to speed on what extended producer responsibility is, let’s help you find the right sustainable packaging solution for your product. Simply give us a ring on 01926 651451 or get in touch with us using the form below. We look forward to chatting with you soon!