Extended ProducerResponsibility (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 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.

The pEPR proposals are designed to make producers responsible for the full net cost of managing packaging once it becomes waste, alongside setting more ambitious recycling targets for producers, and introducing clear and consistent labelling for recyclability. The costs of pEPR are considerably more than the current system.

pEPR will apply across the UK (England, Scotland, Wales and Northern Ireland). Government has proposed the introduction of a single point of obligation (i.e., a single producer is responsible for the cost of managing a piece of packaging). This will focus the obligations onto those who are best placed to reduce and/or increase the recyclability of the packaging they use, so is most likely to be the brands and retailers.

Ahead of the implementation of pEPR, there will be an interim solution for managing packaging waste arising from businesses. This will be based around the current Packaging Recovery Note (PRN) system, whereby packaging producers purchase PRNs and PERNs to show they have met the recycling obligations for the packaging they have placed on the market, and to support investment in reprocessing.

The new pEPR system will have the same de minimis (minimum level where this is applied) for producer recycling obligations and disposal cost payments as the current PRN system (turnover of £2m and handle 50 tonnes of packaging). But a new lower threshold has been introduced for small companies with a turnover of £1m and handle 25 tonnes of packaging to report their packaging data.

Under the new system, all obligated producers will pay a fee for the packaging they place on the UK market. These fees will be modulated; for example, those who use unrecyclable packaging will be required to pay higher fees than those using recyclable packaging, which should provide an incentive to achieve increased recycling.

It is planned that these fees will help to deliver funding to support additional collections and upgrading of infrastructure to allow recycling of currently unrecyclable materials, or to incentivise greater uptake of reuse and refill business models and systems.

Illustrative base fees have been published and will be updated as more packaging data is reported.

Labelling your packaging to show whether it can be recycled is still an important part in making pEPR work. We know that on-pack labelling is still the first port of call for consumers looking for information on recycling, giving them the confidence to do the right thing. In the short term, labelling may not be mandatory, but providing a trustworthy label that encourages participation in recycling is still key.

The first EPR fees are now due in October 2025.

All obligated businesses should now be reporting their packaging data. Defra have published a guide to packaging reporting which gives more information. They have also created an online tool which you can use to check if you are an obligated business. 

The regulations that sit behind the reporting have also been published (The Packaging Waste (Data Reporting) (England) Regulations 2022) and we’ve highlighted some of the key aspects in this summary document.