Unpacking Extended Producer Responsibility for packaging (pEPR)

What is pEPR and what does it mean for you?

New government regulations, called Extended Producer Responsibility for packaging (pEPR), mean that brands and retailers will have to cover the costs for their packaging’s collection, sorting, recycling or disposal. The new EPR for packaging system will replace the current Packaging Waste Regulations.

You’ve probably heard a lot about pEPR but are perhaps unsure about what it means for you.

At OPRL, we’re here to help.

We can explain the mandatory recycling labelling requirements element of pEPR and give you the technical tools to create recycling labels so you can get ahead and start updating your labels now as the clock is ticking and the introduction of mandatory labelling is closer than it may at first seem. We can also amplify your voice at key discussions with powerful decision-makers.

We have a seat at the table across many industry-based conversations and our opinions and voice are widely respected. In addition, OPRL’s Managing Director, Margaret Bates, has been seconded to the Department for the Environment, Food and Rural Affairs (Defra) as Head of the pEPR Scheme Administrator.

To help you get your head around pEPR, we’ve answered some key questions:

What will pEPR mean in practice?

Brands and businesses across the UK (England, Scotland, Wales and Northern Ireland) will be responsible for the end-of-life cost of the packaging they place on the market, including its collection, treatment and recycling.

Businesses will pay the government a scheme administrator cost and a fee related to how much packaging waste they generate, the materials from which it’s made and how recyclable it is.

Businesses will have to report on the amount of packaging placed on the market, and also have to report on the UK nation in which the packaging is both supplied and discarded, so the respective governments can gather national data.

When is pEPR being introduced?

In July 2023, DEFRA announced a delay in the implementation of pEPR. You will not have to pay any fees in 2024, however, you must still report your packaging data (first data submission has already passed) for 2023 and must continue to pay any fees due under previous regulations. The first pEPR fees are now due in October 2025.

Does pEPR relate to all packaging?

No, it’s about household product packaging and any shipment packaging sent to the consumer, such as the wrappers, boxes, films, trays and delivery packaging that contain consumer products – from grocery items to white goods.

Business-only packaging, such as that used by wholesalers, is exempt.

What does pEPR mean in terms of packaging labelling?

Under pEPR regulations, all packaging must be labelled to show consumers if it can be recycled. This will be regardless of business size.

The government has proposed a single-label design using the Recycle Now Swoosh and a simple ‘Recycle’ or ‘Do Not Recycle’ instruction – matching guidelines developed as part of the OPRL labelling scheme. All new packaging types will be required to be labelled by 1 April 2027. Packaging already on the market will not need to be labelled retrospectively.

What is the thinking behind pEPR?

The current system of producer responsibility for packaging, the Packaging Recovery Note (PRN) system, has been in place in the UK since 1997 and has helped to increase the recycling of packaging waste from 25% to 63.9% in 2017. However, as with any system that is over 20 years old, it needs reform.

What is the aim of pEPR?

The aim of pEPR is for producers to pay the full net costs of managing and recycling the packaging waste arising from products they place on the market.

This will encourage producers to reduce their use of packaging and use packaging which is easier to recycle. Producers will pay more for less sustainable packaging, incentivising packaging that uses less material and is easier to recycle. Producers will also be expected to meet ambitious new recycling targets and use clear unambiguous labelling of recyclability to make it easy for consumers to do the right thing.

Which companies must comply with pEPR?

In the UK, pEPR requirements will apply to organisations that import or supply packaging and meet the following criteria:

You’re an individual business, subsidiary or group – but not a charity
You have an annual turnover of £1 million or more
You were responsible for more than 25 tonnes of packaging in 2022

How do you keep your pEPR fees as low as possible?

pEPR includes modulated fees that will initially be based on the recyclability of the packaging. You can keep pEPR costs to a minimum by improving your packaging recyclability – like ditching problematic materials, switching to recyclable alternatives and removing unnecessary design elements. We can advise you on these issues.

Is there any evidence to show that pEPR works?

Research from places that already have pEPR schemes – including British Columbia and Quebec in Canada, Belgium, the Netherlands, Portugal, South Korea and Spain – shows that it substantially improves recycling rates.

How can brands get ready for pEPR?

You need to be collecting your packaging data. Even though pEPR fees have been deferred, you should have already reported your 2023 data, and face potential fines if you haven’t.

We Go Beyond The Label

At OPRL, we are more than just a source of recycling labels. We offer a whole range of related services.

To find out more about how we can help you and your business with your recycling labelling needs and the benefits of becoming a member of OPRL, click here.

Existing OPRL members can log into our Members Area to access our pEPR-compliant Labelling Tool, read our Labelling Rules, access exclusive webinars and information, and much more.

Get in touch with our team if you would like to discuss how we can support you.