Extended Producer Responsibility (EPR) Update

What you need to know.

Defra (Department for Environment, Food & Rural Affairs) have now confirmed that the draft EPR for packaging (pEPR) regulations have been sent to the EU and WTO on the next stage of their journey bringing closer the governments commitment to introducing pEPR by 2025.

The legislation will be brought before the UK parliament later in the year, with the aim of coming into force 1 January 2025.

Below are the key elements relating to the mandatory labelling of recycling information that you need to know about:

• Primary and shipment packaging will be required to be labelled using the Recycle Now mark and relevant wording (Recycle/Do Not Recycle).
• Any packaging where the surface area of the largest surface of the packaging is less than 25cm² is exempt from labelling.
• Brand owners, packer/filler importers, or the first UK owner will be required to label their packaging.
• All packaging types will be required to be labelled by 1 April 2027. This will be for all new packaging going onto the shelf and will not need to be applied retrospectively to packaging already in the market.
• Distributors (of unfilled plain packaging) will be required to provide packaging recyclability information to the small businesses they supply – some flexibility as to how the users provide that recyclability information to consumers.
• Where primary packaging consists of multiple components, one label can be placed on outer component indicating if each component is recyclable or not; or a label can be placed on each packaging component.
• Labelling font sizes must adhere to specific guidelines depending on whether largest surface of packaging is above or below 80 cm².
• Recycling information must also be provided for medical packaging but can be on a leaflet accompanying the product or device inside the packaging; or electronically sent to the person for whom the product or device is being provided instead of a label.
• A recyclability assessment is required to determine the recyclability of the packaging.
• Recyclability assessments need to be saved for at least 7 years and produced on demand.
• If a producer is unwilling or unable to provide sufficient information, then packaging will be deemed as worst in class, and charged as such.

You can find the full details of this latest draft here – The Producer Responsibility Obligations (Packaging & Packaging Waste) Regulations 2024.

You can also find more information on the Gov.uk page:   Extended producer responsibility for packaging: who is affected and what to do

If you have any queries or concerns, please contact your Roberts Mart Sales Manager.