EPR: What is Extended Producer Responsibility?

9 August, 2023
EPR: What is Extended Product Responsibility UK

EPR: Extended Producer Responsibility – A complete guide 

The reforms introduced in existing policies have been a critical doorway to further efforts to ensure sustainability in business operations. Recently, the government has designed Extended Producer Responsibility (EPR) to incentivize select groups of supply chain participants. This policy holds producers responsible who are directly involved in the collection, segregation, and disposal of product packaging. These companies are liable for the full net cost 

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is a policy approach that holds producers responsible for the environmental impact of their products throughout their lifecycle, including after they have been used and discarded. The goal of EPR is to shift the responsibility for managing the environmental impacts of products from the end-user or consumer to the manufacturer or producer.

EPR programs are designed to encourage producers to take more proactive steps to reduce the environmental footprint of their products. This includes designing products for easier recycling, reducing the use of harmful materials, and ensuring proper disposal or recycling of products at the end of their life.

Table of contents:

What is the requirement of an EPR system? 

The main motive for introducing this policy is to achieve a significant level of reduction in the impact of products manufactured on the environment. The base is simple: If waste is produced, the concerned should also be held liable for the impact on the environment. The aim of introducing this policy is to create a stronger circular economy where waste can be reintroduced into the economy. 

  1. Reducing unnecessary packaging
  2. Shifting from single-use packaging to reusable models by improving the design 
  3. Improving the quality of packaging which is favourable for the circular economy 

How does EPR work?

  1. Product Design: Producers are encouraged to design products that are environmentally friendly, easily recyclable, and have reduced environmental impacts throughout their lifecycle.
  2. Waste Collection and Management: Producers are responsible for financing and establishing systems for collecting, recycling, and properly disposing of their products at the end of their useful life.
  3. Financial Responsibility: Producers bear the financial responsibility for the collection, recycling, and disposal of their products, which incentivizes them to design products that are less harmful to the environment.
  4. Regulatory Framework: EPR programs are often established through regulations or legislation that outline the responsibilities of producers, guidelines for recycling and disposal, and penalties for non-compliance.
  5. Collaboration: EPR programs often involve collaboration between producers, governments, recycling industries, and other stakeholders to create efficient and effective recycling and disposal systems.

Businesses impacted by EPR legislation 

According to the policy, any company that handles more than 25 tonnes of packaging and has a turnover of more than 1 million euros needs to report the packaging but doesn’t have to financially contribute. However, if your company/business handles more than 50 tonnes of packaging and has a turnover of more than 2 million euros, the obligation to pay for EPR shall be imposed. This includes: 

  1. Brand owners: Brands that sell packaging solutions to businesses. If the brand is unidentifiable, the organization that is responsible for packaging is responsible. 
  2. Importers: Those who import packaging material 
  3. Online marketplace: Marketplace that facilitates the sale of packaging products from non-UK dealers to UK-based businesses. 
  4. Service providers: Who hire or lend reusable packaging materials 
  5. Distributors: Who import or manufacture different packaging materials and deliver directly to UK businesses. 

Non-profits and charities are exempt from the list, even if they have to sell packaging-related products. 

In case of doubt, organizations can use the online EPR obligation checker developed by DEFRA. It will help you know if you meet the requirements. 

Important Facts about EPR Policy 

The collection of this data would start in January when the first six months of data are required to be submitted between July and October 2023 for a large organization and January to April 2024 for a small organization. 

There will be many UK companies that may be affected, so there will be a revision in the reporting process that captures data. 

The fee shall depend on the cost involved and the amount of packaging waste produced. This will be revised and standardized based on certain waste disposal assessments. This may require more informative data on the packaging materials than just based on the current system for a fair charge. 

What are the current actionable steps involved under Extended Producer Responsibility? 

Small business 

  1. Check if your company is responsible to comply with the EPR system and register for the EPR for packaging online. 
  2. Maintain the data record of packages handled in the US market from 1st January 2023.
  3. Submit the data for 2023 between 1st January 2024 to 1st April 2024. 


Large organizations 

  1. Register for the EPR packaging online and check the requirements 
  2. Have a systematic data record of package handling in the UK market from 1st January 2023. 
  3. In the case of import business, purchase packaging recovery notes and packaging waste export notes to comply with necessary responsibility. The PRN system will be customized and have a single point compliance onto the organizations. 
  4. Pay the fee as suggested by the environmental regulator. 
  5. Submit the data for 2023 between July and October 2023. 

Producers that use more unrecyclable components shall be subject to higher fees. The fee collected will be used to improve the recycling infrastructure. In the full cost payment, producers of single-use packaging will also be liable for the litter management cost of the packaging. 

Details that businesses need to provide in the report shall also include: 

  1. Category of packaging: Primary, secondary, or tertiary? 
  2. Where will the waste be found?
  3. What are the elements and parts of the packaging unit? 
  4. What elements can harm the recycling process?
  5. What elements can improve the recycling process?
  6. What is the design of packaging and layers of material used?

What is the cost of Extended Producer Responsibility to businesses? 

EPR will be modified according to the supply chain structure. In such cases, the cost shall be divided between manufacturers, middlemen, and distributors at different points. 

  1. 6% to manufacturers of resources used in packaging 
  2. Upto 9% to businesses that create packaging products from the resources 
  3. 37% to businesses that uses the packaging materials for their products 
  4. 48% to businesses that sells the final filled package to the end user. 

This will be replaced by 100% compliance from one particular business – which owns or imports the packaging materials and fills the final packing. 

Preparation for Extended Producer Responsibility by the business 

  1. Review and assess the packaging options available, the percentage of recyclability, and how is it recycled. 
  2. Scheduling plan for reporting for at least two submissions. 
  3. Recording the packaging data based on different materials and components. 
  4. Taking assistance from accounting or environmental consultants with any developments and changes in the EPR reporting. 

Preparation is crucial and it is essential to send the report packaging, this will help with the EPR transition. 


What is Extended Producer Responsibility?

Extended Producer Responsibility (EPR) is a policy that makes manufacturers responsible for their product’s environmental impact throughout its lifecycle, from creation to disposal.


What is the purpose of EPR?

EPR aims to reduce product-related environmental harm. Manufacturers become accountable for recycling, waste management, and designing eco-friendly products.


What is the process of EPR?

In EPR, manufacturers manage product disposal, recycling, and environmental impact. They fund collection systems, and recycling facilities, and encourage sustainable design.


Who needs an EPR certificate?

Manufacturers producing goods covered by EPR regulations must obtain an EPR certificate. This ensures compliance with responsible product lifecycle practices.


What are EPR rules in the UK?

EPR rules in the UK require manufacturers to fund the recycling and disposal of their products. New regulations focus on minimizing waste and promoting sustainable production.

What are the benefits of EPR?

EPR benefits include reduced waste, enhanced recycling rates, eco-friendly product design, and minimized environmental impact, promoting a greener future.

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