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July 2023

5 min read

EPR Implementation

Consumer Waste (Waste Offsetting)

To date in Compliance at a Glance, we have focused on the EPR reporting requirements for packaging placed on the market data. In our July issue, we will focus on packaging waste reporting, specifically “Consumer Waste” (waste offsetting).

What is Consumer Waste?

Consumer Waste is certain packaging wastes that producers have collected from consumers. Producers will not incur any Local Authority Waste Management Costs from the Scheme Administrator for the tonnage of any household packaging they have collected and reported as Consumer Waste.

Producers operating take-back systems for household packaging waste can report the quantity that they have collected as “Consumer Waste” in their EPR submission, provided each of the following criteria are met:

  • it is not commonly collected by Local Authorities – see List of commonly collected packaging wastes ; and
  • the producer has placed the relevant packaging material on the market and has reported this as household packaging; and
  • they can evidence that the packaging collected is recycled.

Whilst front of store collections are typically cited as the example of Consumer Waste, producers collecting packaging which is removed from consumers premises when providing a product delivery and installation service can also report this as Consumer Waste, provided the criteria above are achieved. This is unaffected by commercial arrangements and can include packaging collected from products:

  • sold directly to a consumer; or
  • sold to a commercial customer, with a delivery, installation and packaging removal service at their consumer customer’s premises

Consumer Waste can be reported in both of the above situations, irrespective of whether the consumer or commercial customer supplying a consumer is subject to a charge for removal of the packaging.


What are the evidence requirements to demonstrate that the packaging has been recycled?

The Defra Guidance does not currently provide any examples of the evidence that producers should retain to demonstrate that the packaging collected is recycled. At stakeholder events, they have stated that weighbridge tickets and waste transfer notes that demonstrate the separate collection of packaging from producer’s premises would be reasonable evidence.

Producers that combine Consumer Waste with other packaging waste at their premises will need to use additional data sources since Consumer Waste will not be separately identified from other packaging waste in this data.


Producer Accounts on Defra’s Report Packaging Data (RPD) system

As we have previously advised, producers will be required to open an account on Defra’s online system before their packaging data can be reported. Defra have communicated a delay in this system going live, with producer access now being available from 16th August 2023.

EPR Packaging Data Forms

We will be sending all REPIC packaging scheme members the forms that they will need to complete for their January to June 2023 packaging reporting in early to mid-July 2023

Data Form EPR ROOM

We will hold an EPR Data Form ROOM for our packaging members on Tuesday 18th July 2023 to discuss the data forms and answer your questions on their completion. We will send you details of how to register shortly.



The deadline for you to provide us with your Q2 2023 EEE and Battery placed on the market data is 21st July 2023.

As this is the first submission using our new portal please take care to follow the guidance at the top of the EEE placed on the market data screen.

Once you have entered your EEE POM data for each category in kilograms click “Totals” at the bottom of the screen then click “submit”.

If you have any questions please get in touch with Jack or Janette

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