Developments in the 'Extended Producer Responsibility for Waste Packaging' Legislation

woman holding recycling box

The UK government has introduced a new legislation called Extended Producer Responsibility (EPR) for waste packaging. This environmental policy is intended to transfer the costs of dealing with household packaging waste to the organisations that produce it.

Overall, it is expected that (upon full implementation) the cost of packaging waste obligations within the supply chain will more than double. Who in the supply chain directly pays the tax may change depending on whether your organisation is classified as large or small under the EPR legislation. However, even if you are classified as small under the regulations (annual turnover of between £1m and £2m and more than 25 tonnes of packaging) it is certain that most of your suppliers will need to pass on the additional costs.

The intention when fully established is that costs will be collected by a new government agency - not yet set up - from the organisations that put the packaging on the Market, i.e. the Brand Owners. The money raised will be distributed to local councils to pay for household collection and recycling.

Will we all see reductions in our council tax bills from moving these costs? Or is this simply an additional tax? The government has not answered these questions satisfactorily.

This is a news story that keeps evolving. On 5th September the environment agency issued a Regulatory Position Statement (RPS) , announcing a delay to the implementation of EPR fees. The reporting requirement continues. However, costs will now be implemented in 2025 and the modulated fees will not be introduced until October 2026.

Where are we now?

Small organisations need to report on all packaging handled from January 2023 by April 2024.

Large organisations (annual turnover of £2m+ and more than 50 tonnes of packaging) need to report every six months. So, the data for the first half of 2023 is due by October 2023 and the data for the second half of 2023 should be presented before April 2024.

Although you can do this yourself, we would advise registering with a compliance scheme such as Valpak or Beyondly who can support you through this process. In either case you will need to create an account on the Government website and indicate who will be reporting for your organisation .

We will continue to monitor how the current situation with EPR develops and update on possible implications of the EPR legislation in future blog posts.

If you are an existing or potential client of Coda Plastics and you have any concerns about the impact of EPR on your business, please don’t hesitate to get in touch. We may (for instance) be able to find a manufacturing solution that will reduce the weight of your packaging. You can call our office on +44 1692 501020 or email any questions to

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