How can UK organisations prepare for extended producer responsibility for packaging?

UK organisations responsible for packaging will soon need to carry out their recycling responsibilities differently – are you prepared?

CREDIT: This is an edited version of an article that originally appeared on gov.uk

Businesses affected by the new extended producer responsibility (EPR) for packaging will soon be required to report their packaging data. The regulations will apply to all UK organisations that handle and supply packaging to consumers and to businesses. 

If any of the following apply to you, you will need to report packaging data – are you:

• an individual business, subsidiary or group (but not a charity);
• a business with an annual turnover of £1m or more (based on your most recent annual accounts);
• responsible for over 25 tonnes of packaging in a calendar year (January to December);
• a business which carries out any of the specified packaging activities.

Packaging activities

In terms of ‘packaging activities’, you may need to act if you do any of the following:

• supply packaged goods to the UK market under your own brand;
• place goods into packaging that’s unbranded when it’s supplied;
• use ‘transit packaging’ to protect goods during transport so they can be sold to UK consumers;
• import products in packaging;
• own an online marketplace;
• hire or loan out reusable packaging;
• supply empty packaging.

If your organisation sells packaged goods labelled with its own brand, you may also need to report your data. A ‘brand’ includes any of the following:

• a logo;
• a trademark;
• any distinctive mark.

You may also need to take action if you pay another company to carry out part of the supply chain for you. For example, you may pay another organisation to do any of the following:

• produce goods that will be sold under your brand name;
• pack goods that will be sold under your brand name;
• place your branded goods on the UK market;
• import goods for you.

If you place goods into packaging, and that packaging is unbranded when it’s supplied, you may need to take action. This could involve goods you packaged for your own organisation or for another organisation.

You may need to take action if your organisation imports products from outside the UK, in primary, secondary or shipment packaging, and then goes on to supply these products to the UK market – even if you discard packaging before selling the goods. You will not need to take action if you simply import goods on behalf of another organisation.

An online marketplace is a website that has been set up to allow non-UK organisations to sell their goods online. If you own an online marketplace you may need to take action, but if your organisation owns a website that sells goods from UK organisations only, this is not classed as an online marketplace.

Finally, if you hire or loan out reusable packaging, you may need to take action.

Full guidance on preparing for EPR can be found here: Packaging waste: prepare for extended producer responsibility – GOV.UK (www.gov.uk)