UK’s Defra urges businesses to prepare for EPR, warning of £46.5M “familiarization” costs
13 Oct 2022 --- The UK’s Department for Environment, Food & Rural Affairs (Defra) has updated its extended producer responsibility (EPR) guidelines, requiring British businesses that handle or supply packaging to begin collecting relevant data on product origin, weight, trade and other parameters by January 2023.
The announcement comes after Defra postponed the planned EPR implementation earlier this year until 2024 at the earliest, citing implementation concerns. The department’s complex guidelines, which dictate varying requirements according to the size and turnover of any given company, along with the materials they use, are expected to cause confusion once enforced, and likely incur heavy costs for industry as it transitions.
Robbie Staniforth, innovation and policy director for compliance scheme Ecosurety, which helps businesses abide by legislation, tells PackagingInsights that Defra’s update is a necessary clarification on an intricate topic.
“Packaging producers will welcome this much-needed guidance that provides additional detail on how the system will work. Compliance schemes, like Ecosurety, have been gearing up to help members with their data for some time now,” he says.
UK packagers must begin filing data as of January 2023.“This update gives the green light for producers to engage with compliance scheme data experts to get their data ready for the deadline.”
Transition costs
One of the most concerning aspects of the transition into EPR is that businesses will be unaware of their obligations once the legislation enters into force. The legal changes vary according to a company’s annual turnover, called “small” between £1 million and £2 million (US$1.1 - 1.2 million), or “large,” with a turnover of £2 million (US$2.2 million) or more.
Moreover, companies will need to purchase packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet their recycling obligations. They will also need to submit information about where their packaging has been sold, hired, loaned, gifted or discarded.
Actions will also need to be taken according to product weight, material types, logo and trademarking standards and import and export licenses. Since the guidelines are so complex, packagers in the UK are being advised to seek professional consultation during the transition period.
“In Defra’s Impact Assessment, they estimated that it would cost industry £46.5 million (US$53 million) in ‘familiarization’ costs to get prepared for the change,” notes Staniforth.
Familiarization means, for example, producers will have to train staff to understand the new regulations. They will need to set up new systems and possibly teams to handle new requirements.
Policy postponements
The long-awaited implementation of EPR in the UK has added to the confusion. This year, Defra concluded a consultation period in which it debated how the scheme should work and be phased in.
“The delays in deciding on the final system design and releasing guidance has meant packaging producers have been unable to adequately prepare to date,” continues Staniforth.
He stresses that packagers must be aware of how drastically the legislative landscape is about to change.
“We hope this guidance will encourage producers to get started with organizing their complex data sets so they can accurately submit information in a year’s time. It is important to note that the information submitted in the past bears very little resemblance to what will need to be submitted in future.”
By Louis Gore-Langton
