Extended Producer Responsibility is a policy where producers are responsible for the entire lifecycle of products they place in the supply chain. The laws were created to incentivise producers to design more sustainable products, reduce waste and increase recycling rates.
This law applies to manufacturers, online retailers and any business exporting and importing packaged goods to and from the European Union (EU). The UK also has similar laws, created in 2023, with the next submission deadline for packaging data due on the 1st of April 2026. In the UK, this is applicable to any company with an annual turnover of £1 million or are responsible for importing more than 25 tonnes of packaging into the UK per calendar year. Companies under this threshold are obliged to report their annual packaging data but are exempt from fees.
Companies that are affected must register with national EPR schemes, report the types and amounts of packaging used, pay the fees based on the material types used and ensure proper labelling and waste management compliance. This year will be the first year both EU and UK companies will have to pay fees. Fees are eco-modulated, meaning you will pay more packaging that is harder to recycle and less for packaging that is easier.
If you are a company with an annual turnover of £1 million or are responsible for importing more than 25 tonnes of packaging into the UK per calendar year, you will need register with the relevant EPR scheme, report the materials used in that packaging, along with any other packaging used in your products, and pay the fees.
Packaging companies are almost certainly affected. Fees per tonne have been introduced and companies will be looking to pay £215 per tonne of paper or board, £240 per tonne of glass, £320 per tonne of wood and £485 per tonne of plastic. These fees will be determined by the Recyclability Assessment Methodology (RAM) and used to implement eco-modulated fees.
The eco-modulated fees attached to the EPR regulations originate from the ‘polluter pays principle’, which is a commonly accepted practice whereby the producer of pollution should pay the cost of managing it to reduce environmental damage. The ‘polluter pays principle’ is a concept that originated from the ‘Earth Summit’ held in 1992 between global world leaders.
EPR is of course a step in the right direction. Environmental concerns need to be dealt with and as manufacturers, it is our responsibility to manage it. However, there are significant concerns for business. EPR can increase costs for producers, particularly smaller businesses that use unsustainable materials to make packaging. Businesses also face severe penalties if they do not ensure compliance, with some businesses at risk of failure due to increased operating costs. On the other hand, regulation can drive innovation and the development of cheaper and more sustainable packaging, so there are significant pros and cons for manufacturers.
If you would like to learn more and/or receive support on EPR please get in touch today.