The regulations on extended producer responsibility (EPR) apply in many European countries. In a short series, we address the regulations outside of Germany. A special case in this regard is the United Kingdom. The beginnings and considerations of EPR for plastic packaging date back to the country's time as an EU member. As a result, many provisions are similar to those of the EU, but not all.

On 28 February 2023, the regulation „The Packaging Waste (Data Reporting) (England) Regulations 2023“ came into force. This regulation obliges companies that manufacture, use, or sell packaged products to collect and report data on the quantity and type of packaging they place on the market in the UK. This data is used to calculate the fees these companies must pay to cover the costs of take-back and recycling of these packaging materials under the extended producer responsibility (EPR) system for packaging, which started in 2024. Further information on the systems can be found here.

The National Packaging Waste Database currently lists 40 recycling schemes that have successfully registered. With the EPR for packaging, product and packaging manufacturers, as well as those placing packaged products on the market, are required to take responsibility for the environmental impact of the packaging they supply by covering the costs of collecting and disposing of this packaging once it becomes waste. This measure aims to create a financial incentive to reduce the amount of packaging they supply/use and to improve the recyclability of their packaging.

The goal of the legislation is to require manufacturers to pay an EPR fee to local authorities via a system administrator (SA), based on the amount of packaging they supply. The Packaging and Packaging Waste (Producer Responsibility) Regulations 2023, which include provisions for the introduction of EPR, came into force in December 2023.

The provisions in "The Packaging Waste (Data Reporting) (England) Regulations 2023" require manufacturers in the UK to collect and report packaging data from March 2023 (or from January, if available). This data is necessary for the calculation of the EPR fees that manufacturers must pay and is therefore critical for the full implementation of EPR.

Who needs to report what?

Companies with an annual turnover of over £1 million or those responsible for more than 25 tonnes of packaging are subject to these regulations. Obligations include the collection and reporting of packaging data, payment of waste management fees, obtaining recycling evidence (Packaging Recovery Notes [PRNs] or Packaging Export Recovery Notes [PERNs] for packaging exported abroad for recycling), and possibly payment of fees to administrative bodies. Packaging data must be reported via the „Report Packaging Data“ (RPD) portal. However, the collection of EPR fees has been postponed until 2025. Nevertheless, companies must follow the guidelines and report their data for 2023. Details on packaging definitions, affected activities, and specific requirements can be found on the UK government website nachgelesen werden.

The charges were initially scheduled to start in October 2024 but will now be implemented from October 2025, with the exact amounts still to be confirmed. In mid-August 2024, the Department for Agriculture, Environment and Rural Affairs (DAERA) published estimated base fees for businesses, ranging from lowest, middle, and highest costs per tonne for 2025/2026. For example, the costs for one tonne of plastic packaging are estimated to range between £355, £515, and £610.

According to Aussagen von DAERA, more precise figures for base fees are expected to be published in September 2024.

In the future, the EPR fee will also depend on how well the packaging can be recycled. The fee is expected to be lower if manufacturers use packaging that is easier to recycle.

Deadlines

Large companies must report semi-annually, while smaller companies, which fall below the above thresholds, must collect their data for 2023 but are not required to report it. Data for 2024 must be collected and submitted via the UK government portal by April 2025. Specific deadlines vary depending on the part of the UK, including special regulations in England.

The guide​​​​​​​ „Extended producer responsibility for packaging: who is affected and what to do“

provides UK businesses with important guidance on whether they fall under the regulation and what steps they need to take.

Further information:
Claudia Hoese
Customer Relationship Manager, RIGK GmbH
Tel.: +49 611 308600-12
hoese(at)rigk.de