Hot on the tail of the new Plastic Packaging Tax that was implemented in April this year (2022), further reformed packaging waste regulations are in the pipeline for 2024. The purpose of these regulations is to reduce environmental harm and increase the responsibility on producers to develop sustainable and recyclable packaging. The regulations are part of a raft of packaging legislation reforms that include the plastic packaging tax on producers, as well as a proposed consumer deposit return scheme for recyclable containers – something that is already well tested and established in the USA, Norway, and other countries.

This article explains the main proposed regulatory changes and how they might affect your business.

Extended producer responsibility (EPR) and the PRN system

The Extended Producer Responsibility requirements introduced by the new regulations will build on the current Packaging Waste Recovery Note (PRN) system, with larger costs for most businesses classified as ‘producers’ under the present laws.

How does the PRN system work?

The PRN System was implemented by the Packaging Waste Regulations (1997), which defined any business that handled more than 50 tonnes of packaging per year, with a turnover of £2 million + as producers with obligations for responsible waste handling and recycling.

Producers are obliged to purchase a sufficient number of Packaging Waste Recovery Notes (PRNs) to offset the costs of waste handling and recycling. These are purchased through Packaging Compliance Schemes for different types of recyclable materials, including paper, plastic, wood, glass, aluminium, and steel. In principle, the PRN system is a straightforward ‘the more you use, the more you pay’ arrangement designed to ensure that large producers shoulder a fair share of the costs of waste management. In practice, however, the cost of PRNs is heavily influenced by supply and demand, with prices fluctuating due to supply in comparison to annual targets set by the government. Higher PRN prices inevitably have a greater impact on smaller businesses than on their larger competitors.

What is extended producer responsibility (EPR)?

None of the obligations on producers from the 1997 regulations are negated in the upcoming changes. Instead, the principle of Extended Producer Responsibility transfers to producers the public cost of collecting and processing household waste, rather than simply what they use as a business. 

This should, in principle, stimulate businesses to develop more efficient and easily recycled packaging products to offset their costs. Furthermore, as the fees payable will be based on the recyclability costs of the packaging materials produced or handled by the business, this should hopefully end the variability and unpredictability of PRN prices in the current system.

Key changes associated with EPR include:

• Compliance reports every six months on the types of packaging used and their level of recyclability.
• Sales reports on different types of packaging for sales made in each of the UK’s devolved administrations.
• ‘Modulated fees’ for producers based on the recyclability of their products. Unrecyclable products or products that are difficult to recycle will attract higher fees under the new regulations.

Find out more

The new Packaging Waste Regulations are not expected to enter the statute books until 2023, with the revised EPR regime taking force from 2024. A lot can change in this time, but clearly the new regulations imply an increased administrative burden and cost structure on producers compared to the current system.

By preparing in advance and taking steps to improve the level of recyclability of their packaging products, producers can reduce their compliance costs and simplify their reporting responsibilities. Our aim at Kudos Giftwrap is to help businesses deliver the best quality sustainable packaging in alignment with government regulations, consumer demands, and brand requirements, at an affordable price. All our products are optimised for maximum sustainability and ease of recycling, and we are happy to advise you on the best solutions for your packaging requirements to limit your costs under the upcoming changes.

Please call 01923 947519 today to discuss your situation in confidence with one of our packaging support team.