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On 1st May 2024, UK Government notified the draft Packaging EPR Regulations to the WTO and the EU. This is an important stepping stone in the overall process of the reform as following the notification periods, the draft legislation will be brought before the UK Parliament later this year, under the affirmative procedure (commonly used to pass secondary legislation).

The government aims for the packaging EPR Regulations to come into force by the 1 January 2025. There is some degree of uncertainty around this timeline with the General Elections on the horizon.

Draft Packaging EPR Regulations 2024

 

Key changes in the packaging EPR Regulations for retailers to be aware of

  • The addition of recycling targets for 2025-2030
  • Introducing a provision which ensures that if a DRS has not been established by 01 January 2028, producers of drinks containers made of PET plastic, aluminum and steel will be subject to the full range of packaging EPR obligations until a DRS is operational for this material.
  • Amending the labelling provisions so that all labelling obligations will now come into force on 1 April 2027.
  • The removal of provisions on binned waste and litter payments will now be delivered through a separate regulation.
  • The Scheme Administrator (SA) must now provide guidance on the methodology used and factors considered in assessing net efficient disposal costs and effectiveness.
  • Revising the household packaging definition to widen the criteria which allows packaging to become exempt from being classified as household packaging, and therefore exempt from disposal cost fees.

Important information has also been announced in relation to: 

  • When obligated businesses will begin to accrue fees
  • Changes to disposal costs and fees
  • Changes to disposal fee modulation (now potentially open to online marketplaces)
  • 8 changes to the assessment of disposal and public information costs
  • EPR SI has been amended in relation to food waste, fibre-based composite, commonly binned items, duties of regulators, scheme administrator
  • Future regulatory amendments: three provisions will be delivered by amending Regulations in future years, these related to 1) binned waste and litter payments; 2)mandatory cup takeback scheme; 3) offsetting for closed loop recycling schemes
  • Recyclability assessments accreditation: it will not be mandatory to use an accredited or approved third party scheme to undertake recyclability assessments

 Full details on the above is available at the following link: https://defracollectionandpackagingreform.createsend.com/campaigns/reports/viewCampaign.aspx?d=t&c=49036ABB63A4555D&ID=FF8E1BB10868C1A52540EF23F30FEDED&te

Other key announcements:

  • Compliance deadline for packaging data reporting: 31st May is an important deadline for compliance in relation to your packaging reporting obligations. Packaging data for all of 2023 is due in two reports; each covering half of the year. Further details are available here and support is available through a helpdesk (details here).
  • UK Government released a public list of already registered ‘large producers’ for data reporting under packaging EPR – you can access it here: https://www.gov.uk/government/publications/list-of-large-producers-on-the-report-packaging-data-service
  • EPR Fees and call for evidence on eco-modulation: Government intends to release a call for evidence to support finalising our approach to packaging eco-modulation. As part of this release, they intend to publish a set of illustrative base EPR fees.