Extended Producer Responsibility for Packaging - New UK Timeline

Defra’s response to the consultation

As a first step towards implementing the above framework, Defra has announced that the new UK EPR system in relation to packaging will be implemented from 2024 (rather than the original implementation date of 2023).

However, the government intends to develop a statutory instrument covering data collection and reporting obligations for producers which will come into force on 1 January 2023 and be in force until 2024. This means producers will have to prepare for a more detailed reporting system from January 2023. This will include collating and reporting data on specific packaging component materials, which waste stream their packaging is likely to appear in, and the use of any ‘recycling disruptors’ such as metal components. This data will provide the basis for establishing the packaging waste management fees producers will pay in 2024.

The response to consultation document also clarifies that:

The delay from 2023 to 2024 announced by Defra may come as a relief to some producers and those in the re-processing sector who are rushing to prepare for EPR implementation. However it has also caused concern that previously robust provisions, covering the management of business waste, have been watered down. The direction of EPR travel, however, remains the same. The ultimate aim of the EPR system in relation to packaging is still to make producers responsible for the full net cost of managing packaging at the end of its life, and this shift of responsibility is expected to trigger an increase in producer compliance costs of anything between 6 to 20 times, with the costs to industry as a whole set to inflate from the £200-300m a year currently incurred under the PRN system, to nearly £3bn per year.

Because of this, preparations for EPR implementation in the UK, including making sure data collection and processing systems are ready for EPR reporting, remain as crucial as ever.