In the 5th December 2023 Business Readiness Forum and subsequently in the 28th December 2023 newsletter, Defra confirmed that there are some changes to producer’s reporting obligations of 2023 data under packaging Extended Producer Responsibility (pEPR).
Changes for large organisations:
- Large organisations are obligated to collect and record 2023 nation data, but there is no obligation to report this data to the regulator. The deadline for reporting this 2023 nation data was scheduled for 1 December 2024, however, this deadline has now been dropped.
- Large organisations are obligated to retain records of 2023 nation data for at least 7 years.
Large organisations are still required to collect, record and report 2023 placed on market data to the regulator. As a reminder, the reporting deadlines for 2023 packaging data under the 2007 Regulations & pEPR Regulations are:
| Regulations the data reporting relates to | Deadline | Data required to be reported |
| pEPR Data Reporting Regulations | 1 October 2023 | January – June 2023 placed on market data |
| pEPR Data Reporting Regulations | 1 April 2024 | July – December 2023 placed on market data |
| 2007 Regulations | 7 April 2024 | 2023 packaging data |
| pEPR Data Reporting Regulations | 31 May 2024* | All 2023 placed on market data, if producers cannot meet the October/April bi-annual reporting deadlines |
If you use a compliance scheme, it may request your organisation’s data earlier than these dates, so it can verify your data and report to the regulator on your behalf.
* If producers cannot meet the bi-annual reporting deadlines, for 2023 placed on market data under the pEPR Data Reporting Regulations, the Environment Agency are allowing producers some extra time to report. In a Regulatory Position Statementpublished on 5th September 2023, it confirms that no legal enforcement action will be taken on a producer if it does not meet these reporting deadlines, provided that data is submitted by 31 May 2024. This does not relate to data reporting under the 2007 Regulations.
Changes for small organisations:
- Small organisations are obligated to collect and record both 2023 placed on market data and 2023 nation data. But there is no obligation to report this 2023 data to the regulator in 2024 as planned.
- Small organisations are obligated to retain records of this data for at least 7 years.
- Small organisations reporting obligations will be introduced for 2024 placed on market data and 2024 nation data, with the deadline for both on 1 April 2025.
Updated pEPR guides:
Our pEPR guides for both large organisations and small organisations have been updated to reflect these changes to reporting obligations. Please find the latest version (v4) of the guides here.
Should you have any questions on these updates, please contact kerri@btha.co.uk.
