November 2022 update3 min read
It is unclear at this stage if the recent Government changes will affect the implementation timescale for packaging EPR, which is currently scheduled to start taking effect from 2023. Discussions are ongoing within Defra with respect to hitting the first milestones of producer registration and data submission in 2023.
Once implemented, producers that exceed the de minimis and who place packaging on the market that could enter the household waste stream will be required to have two registrations: (1) With a central body, the Scheme Administrator, which is likely to be operated by a Government Department, to fulfill their waste management financing obligation for household packaging. From 2024 this will result in a share of local authority household waste packaging collection costs being allocated to each registered producer; and (2) With either a Producer Compliance Scheme (PCS) or as a Direct Registrant to fulfill their recycling financing obligations for household and non-household packaging. This is largely a continuation of the current Packaging system, where producers pay Packaging Recovery Notes (PRNs) which demonstrate packaging has been recycled on their behalf. Producers that place packaging on the market that only enters the non-household waste stream will register with either a PCS or as a Direct Registrant only. We expect that most REPIC members will be required to register with both the Scheme Administrator and a PCS or as a Direct Registrant.
Whilst the deadline for 2023 registration has not yet been confirmed; discussions are ongoing as to how registration can be best achieved with the least burden to producers.
Packaging EPR will change the definition of a producer and the packaging data you will need to report. Defra is continuing to develop a data template which has been shared in draft with PCSs; it is not as simple as perhaps may have been suggested by the consultation outcome. Whilst the new format will be simpler in many ways; each piece of packaging will only be recorded once, it appears that it will need to be sub-divided by material, packaging layer and packaging activity such as brand-owner, importer or packer/filler and potentially, additional information will be required with respect to plastic bags.
We will continue to engage with Defra via our membership of the Packaging Scheme Forum (PSF) to provide input to the data template design where possible. Given the already tight implementation timescale, we are keen to ensure the Year One (2023) data is as simple as possible and does not exceed the minimum requirements.
Our next Stakeholder meeting with Defra is scheduled for early November, so we hope to have further information to report in our December newsletter.
Need more information? Contact firstname.lastname@example.org
Volunteers needed to test new EEE reporting software
ERIC is due to be replaced during 2023 with a new data entry system, which should make it easier for you to submit and amend your data and to download your company information We will shortly be ready for the first stage of testing and would very much value your input. If you can spare a couple of hours and are willing to volunteer as a tester please get in touch with email@example.com.
We are required to submit your 2023 company registration details to the Environment Agency by the end of November. If you haven’t already done so, please take 5 minutes to log into ERIC and check your company information is up to date – see REP-ACT-0222 for further details.