Extended Producer Responsibility – EPR

A guide to Extended Producer Responsibility (EPR) reporting for Sun Plastics Ltd. clients

At Sun Packaging, we know that navigating new regulations can be a challenge. With the introduction of the Extended Producer Responsibility (EPR) scheme, we want to help you understand your new reporting obligations. We’ve broken down the key requirements to ensure you have all the information you need.

This guide covers the current known requirements for your EPR data submissions. While some details are still being confirmed, collecting your data now is the best way to prepare. For any questions, remember you can always reach out to your personal account manager for support. We’re here to help you get it right.

What’s changing with EPR?

The new EPR scheme aims to make packaging producers, like Sun Packaging and our suppliers, more responsible for the costs of recycling the packaging they place on the market. While much of the existing Packaging Waste Regulations will remain in place—including the need to purchase Packaging Recovery Notes (PRNs)—EPR introduces two main changes:

• New fees for household packaging: You may be charged an additional fee for packaging that ends up as household waste, such as items delivered directly to consumers. These fees will help cover the costs of kerbside recycling.
• Increased data reporting: You will need to provide more detailed information about the packaging you use. This data will be used to calculate modulated fees, which means you could be rewarded with lower charges for using more sustainable and easily recyclable packaging.

Key reporting categories

The EPR scheme requires you to provide enhanced data in three main areas.

1. Base material

You must report on the weight of the following materials used in your packaging:

• Aluminium
• Glass
• Paper/card
• Plastic
• Steel
• Wood
• Fibre composite (a new category for packaging like laminated paper and coffee cups)
• Other (which now requires you to report on individual materials such as biodegradable plastics, cork, and rubber)

2. Packaging type

You will need to classify your packaging into four types:

• Primary packaging: The packaging that is in direct contact with the product, such as a bottle, jar, or can. This type is subject to EPR fees.
• eCommerce or shipping packaging: Packaging used to send items directly to consumers, such as mailer bags or shipping boxes. This is also subject to EPR fees.
• Secondary packaging: Packaging that groups multiple products, such as point-of-sale trays. This is not subject to EPR fees but must still be reported.
• Tertiary packaging: Transit packaging used to protect goods during transport, such as pallets or pallet wrap. This is not subject to EPR fees but must still be reported.

3. Waste type

Finally, you must report on which waste stream your packaging is likely to enter. This is a crucial part of the report, as it determines which packaging is subject to EPR fees.

• Household waste: All primary and eCommerce packaging is considered household waste by default. If you supply packaging exclusively to businesses, you may need to provide evidence to prove it doesn’t end up in a household bin.
• Other categories: You must also report on packaging that falls into categories like street bin packaging (e.g., takeaway food containers), drinks containers, plastic bags, reusable packaging, and self-managed waste (e.g., packaging collected by your own company).

Reporting frequency

The requirement to report, and the frequency of your reporting will depend on the size of your company:

• Large producers: If your company has a turnover of more than £2 million and handles more than 50 tonnes of packaging a year, you must submit data bi-annually and will be liable for EPR fees. Your first report is due in July 2023.
• Small producers: If your company has a turnover between £1 million and £2 million and handles more than 25 tonnes of packaging a year, you must submit a single annual report, and may have liable for EPR fees.
• Micro producers: If your company is below £1 million turnover, you are not required to report EPR figures or fees.

We hope this guide helps clarify your obligations. At Sun Packaging, we are committed to providing you with the best possible service and support. Please don’t hesitate to contact your account manager with any further questions. We’re here to assist you every step of the way.