The UK government is introducing new extended producer responsibility (EPR) for packaging regulations for UK organisations who supply or import packaging into the UK. The requirements under these regulations are being phased in from 2024 onwards.
To support members with the implementation of the new requirements, and to keep members up to date with the latest announcements, we will publishing a monthly member update. This will provide updates on:
- Regulations and governance
- Data reporting
- Guidance and engagement
- Recyclability labelling
- Disposal fees
With the support of our environmental partners Beyondly, we will keep the BTHA packaging EPR member guidance up to date in line with any changes. Members can view and download the BTHA guidance.
Regulations and Governance
The Main pEPR Regulations:
Reminder that the Main pEPR Regulations were notified to the EU & the WTO organisation in May, meaning that the regs are in the public domain to review. You can access here: The Draft Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.
Due to the general election, civil servants had to abide by the pre-election period of sensitivity since it was called (late May), so Defra has ceased all stakeholder engagement and communications. This will pick back up again in mid-July following the election.
Data Reporting
Reminder to submit 2023 placed on market packaging data as soon as possible, as the deadline of 31st May 2024 has passed.
2024 data:
For half 1 (H1) 2024 data submission (packaging placed on market January – June 2024):
- January – June 2024: collect H1 2024 packaging placed on market data
- 1 October 2024: Deadline to submit H1 2024 data to government
For half 2 (H2) 2024 data submission (packaging placed on market July – December 2024):
- July – December 2024: collect H2 2024 packaging placed on market data
- 1 April 2025: Deadline to submit member’s H2 2024 data to government
For 2024 nation data:
- Throughout 2024: collect nation data.
- 1 December 2025: deadline to submit 2024 nation data to government.
Please note that if you use a compliance scheme, it may have internal deadlines for data submissions ahead of the government deadlines, to ensure the compliance scheme can check and verify your data. Please confirm when these deadlines are with your compliance scheme.
Guidance and Engagement
BTHA have updated the large and small organisation pEPR guides, in line with recent updates and 2024 reporting requirements. Please find the updated guides here.
The June 2024 Business Readiness Forum was cancelled as Defra must abide by the pre-election period of sensitivity. We expect stakeholder engagement to commence again following the general election from mid-July onwards.
You can subscribe to Defra’s Resource & Waste newsletter to receive updates.
Recyclability Labelling
A reminder that BTHA’s recyclability labelling guidance document was updated with the change of the deadline to the 1st of April 2027. Please find the document here.
With The Draft Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 publicised on 1st of May 2024, we can now view the labelling obligations here in the SI.
Disposal fees
Illustrative disposal fee rates for the first year of fees (2025 fees, based on 2024 packaging placed on market), have still not been published. Defra were intending to release a Call for Evidence (a type of consultation) to support finalising their approach to the modulation of disposal fees that will apply from the second year of disposal fees (2026 fees, based on 2025 packaging placed on market). But due to the pre-election period of sensitivity, we are now expecting this to be published following the general election. Likely mid-July onwards.
Within the publication of this Call for Evidence, Defra intend to publish their illustrative disposal fee figures for the first year of fees (2025 fees, based on 2024 packaging placed on market), giving producers their first indication of the costs they could incur based on the packaging supplied to the UK market during 2024, which is also expected after the general election. Likely mid-July onwards.
2025 disposal fees timeline:
- 1 April 2025: all 2024 placed on market data should have been submitted.
- April – May 2025: Government will determine invoices for each producer.
- June 2025: Producers will be notified of their final total fees.
- October 2025: Invoices are raised to producers for their fees (these will supposedly be paid in quarterly instalments; we have raised the question of when these quarterly instalment payments will be – waiting for confirmation from Defra).
If members have any questions on the new requirements, please get in contact with kerri@btha.co.uk
