Monday 10th June 2024
As part of our commitment to provide technical advice to customers concerning all aspects of horticulture, we outline below the recent regulatory changes regarding horticultural packaging and waste management.
Extended Producer Responsibility (EPR) is here
Extended Producer Responsibility (EPR) is one of the four ongoing areas of reform in the UK that hopes to incentivise producers to design packaging that is easy to recycle by ensuring that they pay the full net costs of managing the packaging they place onto the UK market.
Does your business need to comply?
EPR Regulations apply to any UK organisation that places over 25 tonnes of packaging onto the UK the market, has a turnover of over £1 million and that supplies products in any of the below “packaging activities”
- products supplied under your brand name
- packaging packed or filled as unbranded
- packaging imported
- packaging supplied as empty
- packaging hired or loaned
- packaging supplied through your online market place
What should you be doing?
Legally, large producers should now have submitted their first two packaging data submissions through registering with the Report Packaging Data Service (RPD) on the gov.uk website. This data submission was due by May 31st 2024. If you have not submitted it, you are liable to be prosecuted.
Your packaging data submission should have include information about:
1. packaging activity – this is how you supply the packaging to the UK Market
2. packaging type – whether it is household or non-household packing
3. packaging class – whether the packaging is primary, secondary, shipment or tertiary
4. packaging material and weight.
For full detailed descriptions of the different types of data see the below links: .Gov Guidance .Gov What to Do
Why is this important?
The submissions that are being made now are providing the data that the scheme is basing the modulated fee costs on. It has been previously stated by DEFRA that £1.2billion pounds needs to be generated from this scheme for the Local Authority’s household waste disposal collection costs. This means that the more companies that supply reliable and accurate packaging data, the more accurately the costs will be represented in the types of packaging being put onto the UK market. Unfortunately, at present, there is still very limited information about the modulated fee costs making it hard for businesses under the EPR legislation to budget moving into next few years. PRN costs will also still be due on top of the EPR costs.
Labelling your Packaging
Under EPR Defra have also recently announced that obligated producer’s requirements to label all packaging materials will be pushed back to April 2027 (originally March 2026). Producers will be required to label their packaging with the “Recycle” or “Do not Recycle” symbols that align with the format and principle of the OPRL labels seen here. Please see the link for some useful information on the labelling requirements. Clarity Guidance on Labelling.
More Waste Regulations…
The UK government has also recently announced the implementation of significant changes to the recycling regulations under the Environment Act 2021. These changes aim to simplify the processes of waste collection and boost recycling rates across the country. From March 2025 for non-household premises such as businesses, hospitals etc (and by March 2026 for households, March 2027 for micro-firms) local authorities across England will be required to standardise the collection of recyclable materials. To maintain cleanliness and hygiene, the requirements will ensure a minimum fortnightly collection of residual waste and a weekly collection of food waste.
To reduce the clutter of multiple bins, the following waste stream divisions are expected:
- Dry Recycling Bin: For paper, cardboard, tins, cans, glass and plastics.
- Food Waste Bin: Dedicated to all biodegradable food waste.
- Residual Waste Bin: For non-recyclable waste.
For more information on both EPR and Simpler Recycling please follow this link: .Gov Advice on EPR
New Government Incoming?
Defra announced last week that they are going to temporarily pause communications with stakeholders in relation to Waste Disposal Reform until after the pre-election period. However, the have ensured that they “continue to prepare for the implementation of our Collection and Packaging Reform programme” which includes EPR and Simpler Recycling.