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
Government is confident that these Regulations will pass through the UK Parliamentary procedure in Autumn 2024 and come into force for 1st of January 2025.
Data Reporting
Reminder to submit placed on market packaging data covering January – June 2024 as soon as possible, as the deadline of 1st October 2024 has passed.
The next reporting deadline is the 1st April 2025, for placed on market packaging data covering July – December 2024.
As a reminder, 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 these deadlines with your compliance scheme.
Guidance and Engagement
‘Illustrative’ disposal fee publication and guidance
Determining if your packaging is household or non-household guidance
You can subscribe to Defra’s Resource & Waste newsletter to receive updates.
Recyclability Labelling
Mandatory labelling is postponed by Government
Government has taken the decision to remove the packaging labelling provisions in the Main pEPR Statutory Instrument (SI), which was notified to the World Trade Organisation and the European Union on the 1st May 2024.
As the mandatory packaging labelling obligation has been removed from the Main pEPR SI, this means that producers will not have an obligation to label their packaging by the 1st April 2027, as previously required, when the Main pEPR SI enters into force in 2025.
However, Government has stated that this removal of the obligation is a temporary position and that they remain committed to implementing a mandatory packaging labelling obligation in the pEPR regime in future, to make it easier for consumers to understand how to recycle packaging correctly.
Government has indicated it will likely bring in a mandatory packaging labelling obligation via an amendment to the Main pEPR Regulations when in force. Government plans to review the incoming EU Packaging and Packaging Waste Regulations, which will replace the Packaging and Packaging Waste Directive that was adopted in the 1990s, to explore if there can be consistency in labelling approaches between the EU and the UK.
Disposal fees
Please review August’s pEPR update for information about the first iteration of ‘illustrative’ disposal fees published by Government.
Government plan to reissue these ‘illustrative’ disposal fees in September 2024 (or early October), based on more accurate 2023 placed on market data received from producers.
