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May 2023

10 min read

Packaging EPR

Latest developments

We are still awaiting responses from Defra to the questions you asked us, we are pressing for an urgent response. In particular, you have provided very helpful information on a range of scenarios relating to brand ownership and contractual arrangements with brand owners that require clarification.

We hope to speak to each of our packaging members individually by the end of May to review progress in implementing the systems needed to achieve the new EPR reporting requirements; if we have not already made contact with you, you should hear from us soon. Please email Vikki Law – – if you need assistance before then, or if you are not one of our current packaging scheme members and would benefit from a little help please also feel free to contact Vikki.


Defra cost calculator

Those of you that attended the latest Defra Business Readiness Forum will know that the cost calculator providing 2023 “base fees” (these are the “Local Authority Waste Management Costs” that producers will be required to pay to finance Local Authority household packaging waste collection costs from 2024, based on the packaging they have supplied in 2023), is currently undergoing internal Defra review and “is due to be published at the earliest opportunity”. The initial cost calculator will be based on the estimated Local Authority Waste Management Costs included in the Impact Assessment that the Government issued with the last Packaging EPR consultation. Four years will have passed since this cost data was estimated so this will need to be considered when using this to calculate your company’s likely 2024 costs. We are hoping Defra will provide some guidance on this when they publish the initial cost calculator.

Defra has advised the following timescales for provision of more up to date cost information on 2023 “base fees”:

  • Revised 2023 base fees – to be published at the end of 2023.The 2023 base fees referred to above have been calculated from estimated Local Authority household packaging waste collection costs in 2019 and the estimated quantity of household packaging that will be placed on the market in 2023. These base fees will be recalculated using an updated estimated quantity of household packaging that will be placed on the market in 2023, using the data submitted by producers for 1st January to 30th June 2023.
  • Final 2023 base fees – to be provided in June 2024.These are the actual Local Authority Waste Management Costs that each producer will pay for the household packaging that they have placed on the market in 2023. This will be based on each producer’s market share of the costs incurred by Local Authorities in managing household packaging waste in 2023.

As previously advised, once the initial Defra cost calculator has been published, we will provide guidance to enable you to produce an estimate of your 2024 Local Authority Waste Management Costs using your 2022 packaging handled data.

Defra has yet to confirm how and when invoices for Local Authority Waste Management Costs will be raised in 2024. It was expected this would take place quarterly from Q2 2024 but Defra could not confirm this at a recent meeting. Again we are pressing for urgent clarification.

Modulated fees

Modulated fees will become payable from 2025, initially to reflect how recyclable packaging is. The base fees referred to above within each material category will be modulated, so for example, within plastic, the modulated fees may be different for expanded polystyrene and low density polyethylene. The total cost to Local Authorities of managing each packaging material will be calculated and divided by the tonnage of that packaging material placed on the market to calculate the base fee as above. The base fees will then be adjusted up or down so that producers of packaging that can be easily recycled will pay less than those whose packaging is difficult to recycle. We understand there will be consultation with producers on modulation, which Defra advises will be “as soon as possible after the summer, but definitely by the end of 2023”.


Signing off your 2022 EEE data and Company registration details

Further to our email REP-ACT-0234 please ensure you take 5 minutes before the 17th May to print your “Registered Company Information” form from ERIC, check your company information is current and your total EEE placed on the market data for 2022 is correct, then arrange for the form to be signed by a registered Director and returned to before the 17th May.

If you need any help please contact Janette –


Expanded chemistry reporting

Thank you for using the new battery reporting template to report the portable batteries your company placed on the market in Q1 2023. We appreciate that the expanded chemistry reporting is currently voluntary, but as explained it is likely to become mandatory in the future. If you require any further assistance or clarification please do not hesitate to contact Jack Studholme

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