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July 2024

Packaging EPR Focus on labelling

We recap on the additional costs that will be invoiced to producers in 2025 when EPR is fully implemented to enable you plan for these in your budget.

In our previous newsletters we have already advised you of the increased costs that producers will incur under EPR and also how you can consider these when preparing your 2025 budgets (see PACK-ACT-0022). We have summarised this information further for you below, as it is important you are fully aware of the changes and make budgetary provision for any increase in your compliance costs.

2025 Local Authority Disposal Fees and Scheme Administrator Costs – impacts producers of household packaging only

Under EPR, producers of household packaging will be responsible for covering the costs that are incurred by Local Authorities in managing household packaging waste and for a public information campaign advising  households how to recycle their packaging. Defra advised in their EPR consultation outcome, that when combined with the operating costs of the new Scheme Administrator, which will administer producer charges and Local Authority payments; this would cost UK producers approximately £1.4bn per annum.

For a considerable time, Defra have promised to release “base fees”, which are indicative costs that producers will incur in 2025 for each tonne of household packaging that they have placed on the market in 2024. As we advised in our June edition of Compliance at a Glance, Defra now expect to provide these in August 2024. Until we have this information, the easiest way for producers to estimate their 2025 costs is to consider the differential between the Packaging Waste Regulation (PWR) regime, which was estimated by Defra as £300m and their estimated additional EPR costs of £1.4b (total EPR costs therefore being £1.7bn). This means that UK producers collectively, will share a potential six-fold increase in their costs under EPR.

2025 PRNs (Packaging Recovery Notes) – impacts all producers

The PRN system that has operated in the UK since 1997 under the Packaging Waste Regulations (PWR), through which producers finance the recycling of packaging waste, will continue under EPR, however, there are important differences. PWR operates under a shared system of responsibility, with all parties in the packaging chain sharing part of the cost of recycling each piece of packaging, whilst under EPR there is a single point of compliance meaning one party is responsible for the cost of recycling each piece of packaging.

It is expected that changes to the type and responsibilities of producers under EPR will increase the quantity of packaging that is obligated. This means that with the exception of wood, the 2025 EPR recycling targets are lower than the 2024 targets currently in place under PWR.

The quantity of PRNs that producers will require in 2025 is based on the type of packaging material that they place on the market in 2024, multiplied by the relevant 2025 EPR target as detailed below:

2025 Regulator Fees – impacts all producers

Producers will incur higher regulator fees under EPR than they have incurred under PWR. The fees below are for compliance scheme members registered with the Environment Agency, with direct registrants incurring higher charges. Northern Ireland producers incur different charges when registered through NIEA for PWR.

Concerned about your 2025 costs?

Mark Frakes, REPIC’s Finance Director, will be contacting our Packaging Member Finance Directors in the coming weeks to ensure that your business is aware of the potential increase in your compliance costs in 2025. If you wish to contact him directly before that, please email mfrakes@repic.co.uk


Quarter 2 EEE and Battery POM data deadline is 21st July 2024.

Please report your 2024 quarter two B2C and B2B EEE data into the portal prior to the 21st July 2024.

To account for the holiday season, we have sent the battery forms out earlier this quarter. Please complete, sign and return the forms prior to the 21st July.  If you are unable to obtain a director’s signature prior to this date please send the unsigned form before the 21st and follow up with the signed form at a later date in July.

If you have any questions relating to either your EEE or battery placed on the market data, please contact Jack at jstudholme@repic.co.uk

WEEE Member – Annual Declaration

If you have not already done so, please download your Annual Declaration from the members portal, check the details are current and your 2023 EEE data is correct, arrange for the form to be signed and returned to jstudholme@repic.co.uk, as soon as possible. Please note that it is a requirement of the regulations that this exercise is completed on an annual basis.

All signatures for battery forms and for the annual declarations have to be from a registered Director as listed on Companies House.

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