Packaging Recovery Notes and Extended Producer Responsibility – What’s in store for 2024. Key dates, prices, and inside industry info.

Dan Pegram

Published: 21/02/2024

Considering recent developments, it is important to stay informed about the key points regarding Extended Producer Responsibility (EPR) reporting.  Here are the key points you should be aware of.

The deadlines laid out in the regulations for reporting packaging data remain in place. As a reminder, those deadlines were:

– Large organisations reporting for January to June 2023 should submit by 1 October 2023
– Large organisations reporting for July to December 2023 should submit by 1 April 2024

However, in September 2023 the government issued a regulatory position statement (RPS) that confirmed that no enforcement actions would be taken if Extended Producer Responsibility packaging data is submitted by: 31 May 2024.

The introduction of EPR fees will now be delayed from October 2024 to October 2025. This fundamentally means that the EPR fees will not apply in the first year of EPR. Government have stated that the delay comes “following extensive engagement with industry and in light of the pressure facing consumers and businesses in the current economic context” and that “the additional year will be used to continue discussions on the scheme’s design with industry and reduce the costs of implementation wherever possible.”

The Scheme Administrator will be setting and charging the modulated fees to producers. As soon as we can, we will indicate what your fees could be in 2025.

EPR reporting is a legal requirement, and it’s essential to submit accurate data. Under EPR producer costs will increase significantly depending on your packaging activity. EPR aims to transfer the entire burden of managing household waste to the producer.  This places a huge financial burden on producers and ensuring your individual packaging component data is correct will result in direct savings in the EPR costs.

Ultimately your product packaging data will drive your compliance costs in 2025, it is important to ensure that you are reporting the correct weights and material to ensure you are mitigating additional compliance costs.

DEFRA launched a new consultation seeking views on how the approach set out in the government response to the EPR consultation held in March 2022 has been reflected in the draft regulations and how easy they will be to implement. As part of the consultation, Defra says it’s looking for feedback on how clear the draft regulations are about the relevant responsibilities of producers, exporters, reprocessors, compliance schemes, local authorities, and the scheme administrator. The consultation closed on 9 October 2023.

The Governments will consider the responses to the consultation and make amendments to the draft Regulations as appropriate.

In 2023, we saw incredible strides in recycling, with quarter-by-quarter improvements highlighted in the data published by the Environment Agency. The final quarter continued this positive trend, even though we experienced a bit of a dance in prices across various materials. Don’t worry—it’s all part of the lively market adjusting to evolving dynamics, signalling that we’re well on our way to meeting the UK recycling targets.

Positive Momentum: In 2023, we witnessed remarkable strides in recycling, with quarter-by-quarter improvements highlighted in the data published by the Environment Agency. The final quarter continued this positive trend, albeit with a price correction across various materials. This correction indicates a market adjusting to evolving dynamics, suggesting that recycling targets are well on their way to being met.

A Solid Foundation for 2024: The market outlook for 2024 is characterised by a positive forecast, indicating an increase in PRN volumes from 2023. This momentum provides us with a solid foundation, instilling confidence as we step into the new year.

Navigating Nuanced Landscapes: While our optimism is buoyed by these positive trends, we acknowledge the nuanced landscape of 2024. Anticipating a dip in PRN demand compared to 2023, we recognise the broader economic sentiment. Consumers, mindful of the ongoing cost of living crisis, interest rate rises, and other financial impacts, may exercise caution in their spending habits.

Challenges and Opportunities: The potential fall in supply each quarter poses challenges, particularly in markets for some materials. As we navigate these potential challenges, it is essential for us to remain agile, adaptable, and informed. Our commitment to providing you with accurate market commentary and budgetary prices is unwavering.

In summary, the PRN market in 2024 is expected to build upon the positive momentum of the previous year, but stakeholders should remain vigilant and adaptive to navigate potential challenges arising from economic uncertainties and changing consumer behaviour.