pEPR: Less than two weeks to submit packaging data

Ahead of the deadline, obligated producers will need to:  

• Large organisations are required to submit their data for July to December last year. 

• Small organisations are required to submit their data for January to December last year.   

• All obligated producers must also register with their environmental regulator by the same deadline. 

The data will be used to ensure that the fees are set at an appropriate level. 

Dr Margaret Bates, head of the UK pEPR scheme administrator PackUK, said: “The need for an effective pEPR scheme that shifts the cost of managing household packaging waste to producers has never been more critical.  

“We urge all businesses to check their obligations under pEPR and to report their data and register with environment regulators by 1 April.  

“Together, we will deliver a fair and collaborative scheme that addresses the challenges of packaging waste and lays the foundation for a more sustainable and responsible approach to packaging.”  

Compliance is key to making pEPR work 

Paul Vanston, CEO of the Industry Council for Packaging and the Environment (INCPEN) and member of the UK’s Packaging EPR Steering Group, told Letsrecycle.com: “Compliance with legislated timelines by companies, councils and others is at the heart of achieving the UK’s packaging reforms.

“This includes all obligated producers meeting registration and data deadlines to ensure a fair and level playing field on allocating EPR costs.”

Louisa Goodfellow, Ecosurety’s policy manager, added: “The environmental regulators – the Environment Agency (EA) in England and their equivalent in the other three nations – have a number of civil sanction and enforcement options available to them to regulate the packaging EPR system, and these powers have been strengthened since the introduction of the new regulations. These can range from compliance notices to variable monetary penalties that could cost businesses millions for more serious offences, including not reporting packaging data in line with submission deadlines.

“Providing accurate and timely packaging data is more crucial than ever, given that this year’s reports will directly affect how much businesses will pay in October. We would encourage producers to submit their data as early as possible to their compliance schemes or directly to the regulators, to reduce the risk of any enforcement action and, crucially, ensure the EPR system is as level a playing field as possible.”

William Gough, operations director at Wastepack, also emphasised the need for compliance: “EPR is a crucial measure for boosting recycling rates, minimising waste, and promoting the creation of more sustainable packaging.

“With the registration deadline fast approaching in early April, Wastepack are pleased to have assisted over 1,500 producers to ensure their data is both accurate and ready for submission by the deadline for their continued compliance. 

“Timely submissions of data as accurate as reasonably possible is essential for maintaining the integrity of the new system. This will provide a clear overview of packaging waste and the UK’s obligations for the 2025 compliance year. 

“With the majority of producers registered with approved compliance schemes, working tirelessly with their members, we hope to see as many obligated producers as possible complete registration by the deadline. This will help support the system and ensure a fair process going forward.” 

A warning of challenges and complexities 

Director of consultancy 360 Environmental Phil Conran warned of the complexity that faces producers under the new system.  

He explained: “For the last two years, large producers have been required to “enrol” and supply packaging data through the Report Packaging Data (RPD) system. This is a new development that will eventually cover reprocessors and exporters and – I assume – will calculate the cost obligations of the £1.5 billion waste fee. 

“For those used to relative simplicity of the old NPWD system, RPD presents significant challenges. Login issues, restrictions on email address compatibility, lack of historical records, erroneous error reports, CSV file complexities and just the shear amount of seemingly pointless information requirements have not endeared the process to those who use it. But large producers have had two years to get used to this without the risk of penalties. 

“However, 1 April heralds the full application of not just the data requirements, but the registration fees and penalties for incorrect or late data. And to further complicate things, 1 April also sees the requirement for small producers – those with £2 to £5 million turnover PLUS over 25 tonnes packaging placed on the market in 2023 – to register. This could add several thousand producers to a system already creaking at the seams who in most cases, will have had no previous exposure to the packaging regulations. 

“What many large producers have yet to understand is that this year they will be required to register and pay the registration fee twice – by 1 April and by 1 October. And whilst the focus has been on the huge cost increases for many created by the waste fee, there is also the potential impact of data on PRN costs. Effective enforcement will be critical to ensure that costs are fairly distributed, and PRN demand is based on accurate data. Evidence to date indicates this will be a challenge.” 

Timeline for pEPR 

Defra intends for pEPR to “move the cost of dealing with household packaging waste away from taxpayers to the businesses who produce the packaging”.   

pEPR was first announced as part of the 2018 Resources and Waste Strategy and the full pEPR regulations were laid in parliament on 24 October 2024.  

A few days before, the government wrote to the steering group to confirm its support for an industry-led Producer Responsibility Organisation (PRO) to be created. The PRO will manage the practical aspects of pEPR. 

In November 2024, local authorities were given the indicative estimates for the payments they will receive as a result of pEPR.  

In December last year, Defra released the final Recyclability Assessment Methodology (RAM) which will determine the fee modulation for pEPR. It also released the third round of base fees which are expected to be confirmed in July 2025. 

In January this year, it was announced that the pEPR scheme administrator would be run as PackUK, headed by Dr Magaret Bates and chaired by Sebastian Munden. 

Earlier this month, Defra announced that Karen Graley had been made the head of the PRO.