November 2023

Packaging EPR

EPR Disposal Fees

The EPR Regulations require producers to reimburse local authorities for the costs they incur in providing a household waste packaging service. The disposal fees will be invoiced by the central Scheme Administrator (yet to be appointed).

First payment due in 2025.

Producers placing household packaging on the market in 2024 will incur local authority disposal fees for that year, calculated from their market share of the costs incurred by local authorities in managing household packaging waste.

Defra’s current Disposal Fee timelines for packaging placed on the market in 2024 are:

  • “Base Fees” (the estimated cost of each packaging material) are to be provided in early 2024
  • Invoices for payment will be issued by the Scheme Administrator, the current timescale for this to commence is in the second half of 2025

Payment due in all subsequent years – 2026 onwards

Disposal fees for household packaging placed on the market from 2025 onwards will be modulated, meaning that the fees payable by producers will be increased or decreased based on recyclability of packaging. Initially, the modulation will be relatively simple, this is known as “early years” modulation and is likely to be based on a “reporting list”. In the longer term this will transition to a recyclability assessment which is referred to as “RAM”.

Initially fees will be modulated upwards only, however, since EPR operates on a recovery of full net cost basis, effectively this means that producers placing other types of packaging on the market will pay lower costs than they would in the absence of modulation.

The materials that will be modulated in 2025 will be confirmed by early 2024.

Which packaging materials will be modulated?

Defra are considering applying modulation for any of the following packaging that is placed on the market in 2025:

Packaging shortlisted for higher fees

 

 

 

 

 

 

 

 

 

 

 

 

 

How you can prepare for EPR Disposal Fees and Modulated Fees

Calculate your potential financial liability for the household packaging you place on the market in 2024 as soon as base fees are available and make budgetary and cashflow provision. We will produce some simple guidance to help you do this.

Consider how you can reduce your costs through:

  • packaging design (reduce packaging usage, or change packaging materials, focusing on opportunities for removing those short listed for higher fees)
  • accurately quantifying your household packaging. You could review your H1 2023 data and identify any primary and shipment packaging that could be classed as non-household if you had evidence that your direct customer discards this. Implement processes to obtain this evidence prior to your H1 2024 data submission.
  • Develop your data collection systems to enable separate future reporting of materials types that may be modulated. Future-proof this by preparing for inclusion of additional categories in subsequent years.

 

WEEE Compliance Fee Methodology for the 2023 Compliance Year

Defra is consulting on whether there should be a WEEE Compliance Fee Methodology for the 2023 compliance year and if the JTA methodology, the only proposal that was submitted, should be adopted.

REPIC has again supported the JTA in their development of a WEEE Compliance Fee methodology for the 2023 compliance year. A compliance fee is an essential feature of an effectively functioning and cost-reflective WEEE system. The JTA methodology mirrors that which worked successfully in the 2022 compliance year, with a minor future focussed modification to reflect the increasing importance of reuse in a circular economy and to establish a new Innovation fund to support projects that increase the life of electrical appliances and support circular economy business models. The methodology again proposes a zero fee for streams that due to their positive value have a high level of collections outside the WEEE system, as is the case for Large Household Appliances (LHAs).

We encourage all our members to support the JTA proposal, through a direct response and/or through your trade association. The consultation is available here. The deadline for responses is 13th November 2023.

Digital Waste Tracking – Government consultation response

Government has produced its response to the Digital Waste Tracking Consultation. The digital waste tracking system, which will be implemented from April 2025, will provide a digital tracking system for all controlled and extractive waste so is relevant both to REPIC and our members who handle waste.

The system will replace waste transfer notes and hazardous waste consignment notes (including pre-notification and deposit copy arrangements in Scotland), however, whilst the movement will need to be recorded on the tracking system, Annex VII notifications will still need to travel with green waste shipments. Waste collected from householders other than by local authorities or their contractor will be tracked in the same way as other waste, however “incidental” waste produced by a tradesperson will be outside of the system until it is first received at a collection point. Other potential exceptions are under consideration.

Whilst the desire is to move to real time information, this was recognised as not being achievable on day 1 and likely to take approximately 2 years for all service users to transition to this. Until this is mandated, all transfers are required to be entered onto the system within 2 working days of the transfer occurring. Whilst it does not appear that producers will be mandated to classify the waste, they will be required to confirm that information entered by others is correct.
Options for use of season tickets for non-hazardous waste are still being explored.
We are keeping the implementation process under close review and will provide further relevant information as appropriate.

Environment Agency consultation – Attendance of technically competent persons at waste sites

The EA has published a second consultation on the attendance requirements for technically competent persons (TCP) at waste sites. This is relevant to our members who have waste permits.

The proposal provides an attendance requirement by charging band, so for example, an installation accepting more than one type of hazardous waste has a TCP requirement of 50% of operating hours, whilst an installation accepting only one type of hazardous waste requires a TCP attendance for 30% operating hours. These attendance requirements are uplifted if a site is regarded as a poor performer.

More information can be found here: Changes to technically competent manager (TCM) attendance at permitted sites – GOV.UK (www.gov.uk)

The deadline for responses is 14th December 2023.

Consistent collections – Government consultation response

Government has published its response to the Consistent Collections consultation and has announced that local authorities in England will be required to collect the same recyclable waste streams for recycling or composting from households, which are paper and card, plastic, glass, metal, food waste, and garden waste The types of waste that are included in each of these are defined e.g. metal includes cans and foil.

Government also intends that all non-household municipal premises in England (such as businesses, schools and hospitals), must make arrangements to have the same set of recyclable waste streams (with the exception of garden waste) collected for recycling or composting. This will therefore affect the majority of our members. Implementation timescales are yet to be confirmed so we will keep this under review and provide further relevant information as appropriate.

 

 

We will be registering our WEEE Scheme members for the 2024 Compliance period at the end of November. If you haven’t already done so, please take a couple of minutes before 15th November to log in to the portal and check your company information is current and correct.

If there are any changes to be made you can make these directly by clicking the edit details button at the bottom of the page. As always if you have any queries feel free to contact either Janette janetteollerhead@repic.co.uk or Jack JStudholme@repic.co.uk

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