Fees
When will the information on the calculation of base fees and modulated fees be made available?
How should businesses accrue for EPR fees?
Any trade from 1 April 2025 is obligated for fees, as per DEFRA/PackUK guidance, but businesses may want to check with their own accountants as per financial year set ups.
Who carries the obligation for imported filled packaging which is branded but where the importation is done independently of the brand owner and where there is no financial or licence arrangement in place with the importer?
The importer would be required to report this packaging in accordance with Regulation 18(3)(b). The brand owner would not report the packaging as Regulation 16(4)(b) stipulates that a brand owner is not a producer in this scenario.
More information can be found regarding responsibility for imported packaging in the Regulators’ Agreed Positions guidance (pages 28 to 30)
Data Reporting
When do I need to submit packaging data by?
Large organisations need to report data every 6 months with the deadlines being 1st April for packaging placed on the market 1st July – 31st December and a deadline of 1st October for packaging placed on the market 1st January – 30th June .
Small organisations must collect and report their 2024 data by 1 April 2025.
How do I find out what data needs to be submitted?
Data that is required to be submitted can be found via the Gov website.
What is the purpose of the nation data reporting and when does nation of sale data need to be submitted?
Waste is a devolved policy. Under the UK’s Extended Producer Responsibility (EPR) scheme for packaging, nation data reporting ensures recycling rates can be tracked, and recycling targets set, at a nation-level.
Nation of sale data for the previous calendar year must be submitted by 1 July each year except in 2025, when the deadline is 1 December. The Environment Agency has issued a grace period where reporting nation of sale data is unlikely to be enforced. This grace period will end 31st December 2026 meaning from 2027, businesses must report this data or risk enforcement.
Is there producer obligations around responding to request from retail customers? For either detailed product-level information on packaging e.g. material type, weight, recyclability, or details regarding our PPT licencing and payment.
EPR
- There is no obligation to share information with your customers.
PPT
- Show They’re Following the Rules: Be ready to give evidence of Plastic Packaging Tax (PPT) registration and payments if retailers ask.
RAM
Labelling
What is the impact of the delay to labelling requirements likely to be?
It is expected that EPR labelling requirements will come in during 2028 subject to consultation.
Advice is to continue with current voluntary labelling schemes for the time being (OPRL).
What is the long-term impact of alignment with the EU? Unintended consequences of dynamic alignment?
Aligning EPR with PPWR will seek to minimise the costs and complexity of the arrangements for those businesses trading across all these markets, while protecting our commitment to the importance of labelling as part of the overall objectives of these reforms.
Litter
When will the Scottish and Welsh Govts announce further details on ground litter obligations?
At present, the Scottish and Welsh Governments haven't shared full details about ground litter rules under EPR. However, both have reviewed and consulted on litter and fly-tipping enforcement, so new policies are expected soon.
Enforcement Models - Litter and flytipping offences - enforcement review: final report - gov.scot
Policy Interactions & DRS
How does material flow in Wales get measured to ensure compliance with EPR when in scope of a separate DRS scheme?
In Wales, waste is tracked through detailed analyses and data collection to meet EPR rules. This continues even alongside a separate Deposit Return Scheme (DRS). The Welsh Government stresses that clear, accurate data is key to shaping policy and enforcing the rules.
Residual waste infrastructure capacity note - GOV.UK
Waste Collections & LAs
How will volume of waste collections be measured?
Waste collection volumes are measured through:
- Local Authority Reporting: Councils report how much waste they collect and how often.
Standard Models: Tools like LAPCAP help estimate average collection volumes and frequencies using consistent methods