What is EPR?
EPR is a new UK environmental policy that makes producers responsible for the entire lifecycle of their products – including the cost of waste management. EPR promotes more sustainable waste management products and practices based on the reduce, reuse, recycle model. Under this policy, producers are responsible for making and selling products, but also for ensuring their sustainable disposal after use.
Producers who import or supply packaging within the UK, are now responsible for the costs of collecting, managing, and recycling the packaging that they place on the market. The goal of EPR is to incentivise business to create more sustainable product design and waste management practices.
How does it work?
1. Registration
- Producers must register with an account via the UK government website to report their data under EPR.
2. Data Submission
Producers must report:
- How much product/packaging they introduce into the market each year.
- Material type (plastic, paper, metal, glass, etc.). This data is used to set their collection & recycling targets.
3. Compliance & Reporting
Producers must submit annual or quarterly reports showing:
- Quantity produced, collected and recycled.
Who needs to make submissions?
- Individual businesses, groups or subsidiary (not including charities).
- Any business with an annual turnover of £1 million or more based on the most up-to-date annual accounts.
- Any business responsible for importing or supplying more than 25 tonnes of packaging into the UK within the previous calendar year.
- Any business carrying out packaging activities.
For full details on submission rules- see the UK government website here.
Is EPR part of Plastic Packaging Tax (PPT)?
No – PPT is a separate tax on plastic packaging items only and has its own rules.
To learn more about PPT click here.
What are the exemptions from EPR?
- Packaging used on goods sold outside of the UK
- Empty packaging sold outside of the UK
- Medical packaging
- Non-household waste packaging
What data is reported?
The type of data you need to report depends on whether your business is considered a large or small business under the EPR eligibility guidelines, as well as whether the packaging is supplied by a business that is established within the UK.
As outlined by the UK government:
“Large producers:
- Packaging activity data – for example, supplying under your brand, packing or filling, or importing
- Packaging type data – for example, if the packaging is household or non-household
- Packaging class data – whether the packaging is primary, secondary, shipment or tertiary
- Packaging material and weight data
- You must also collect information about the recyclability of some packaging… (RAM)*.”
“Small producers:
- Packaging activity data
- Packaging class data
- Packaging material and weight data”
*Product based data- based on RAM classification explained in the point below.
https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility
What is Recyclability Assessment Methodology (RAM) classification?
To submit data under EPR, producers will need to use RAM to classify the material used in their packaging. Fees for EPR are based on how recyclable the packaging is and what material it is made from.
To comply with RAM, producers will have to use a RAG rating (Red, Amber, Green) for their materials based on governmental guidelines and then evaluate their materials against those specified in the RAM standards.
Material types and how they are rated under the EPR RAM RAG guidelines:
| Material | RAG rating- starting point |
|---|---|
| Paper & Cardboard | Green |
| Glass | Green |
| Aluminium | Green |
| Flexible Plastics | Red |
| Rigid Plastics | Green |
| Wood | Red |
| Fibre Based Composite - For Liquids | Amber |
| Fibre Based Composite - For Non-Liquids | Green |
| Other | Red |
What is Viscose’s role in relation to EPR?
- We are enrolled on EPR and submit the required documents on behalf of all our UK customers who are not classified as large producers – according to the scheme rules.
- We have completed RAM classification assessments on all our products, and we pay the relevant fees as set out in the scheme.
- We are actively working to minimise the number of ‘Red’ products in our portfolio to improve recyclability and reduce fees for both our business and our customers. Examples of this include investing in research and development leading to our plastic-free sleeves, using lightweight flexible plastic to reduce tonnage and transitioning customers from untethered to tethered plastic caps.
Sources:
https://www.gov.uk/government/collections/plastic-packaging-tax
https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do
https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility
https://www.gov.uk/guidance/recycling-assessment-methodology-how-to-assess-your-packaging-waste
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