7th September 2022
The way that UK businesses carry out their recycling responsibilities is changing. From 1 January 2023, all businesses that handle and supply packaging must comply with the new extended producer responsibility (EPR) data recording and reporting requirements. These recording and reporting requirements are designed to be in place before the full EPR implementation which starts in January 2024. See our previous article Government confirms delay to EPR scheme roll out.
We’re still waiting for the legislation that lays out the data recording and reporting requirements. However, in the meantime, the Department for Environment, Food & Rural Affairs (Defra) and the Environment Agency have published guidance on how businesses should prepare for the new EPR for packaging. You can read the guidance here.
The guidance sets out:
The regulations will apply to all UK organisations that handle and supply packaging. Businesses within the Food and Drink sector will be particularly affected. You must take action to comply if all the following apply:
Under the new regulations, you may need to:
The steps you must take to comply with the regulations will depend on whether your business is classed as a small or large organisation. You will also be caught if you sell packaging goods to the end user. The data that you collect must be categorised into:
Even though we’re still waiting for the legislation, Defra appears keen for this to all start in January 2023. If you think your business will fit into the above categories for data gathering, you will need to start preparing for this complex data recording process. Our Regulatory and Compliance Team can help you navigate the new EPR for packaging rules. The team has a great deal of experience advising the Food and Drink sector on how to keep up to date with an evolving regulatory landscape.