EPR Guide - Flipbook - Page 26
Practical Compliance Guidance: How to
Meet Your EPR Obligations
Complying with packaging EPR will require coordination across multiple parts of your business, from
data collection in operations to making payments via 昀椀nance. Here’s a step-by-step guide to ensure
you cover all bases, along with tips for logistics, transport, and manufacturing companies:
1. Determine Obligation and Register
Check if you are obligated using the threshold criteria (≥£1m turnover and ≥25 t packaging). If yes,
you need to register for EPR. Registration is done through the online government portal (the “Report
Packaging Data” service) or via a compliance scheme. New producers should register before your
昀椀rst reporting deadline, for most, this will be well before 1st April of the 昀椀rst reporting year.
Tip: Many companies have used compliance schemes to handle registration and reporting,
if you lack internal compliance capacity, consider this route. Ensure that for group
companies, the parent or a designated entity registers on behalf of the whole group.
You will pay a yearly registration fee to the regulator or scheme.
2. Map Your Packaging and Supply Chain Roles
Conduct an internal review of all packaging you handle and your role for each. This
means listing out packaging materials/components used in: product packaging,
transit packaging for shipments, any distribution packaging, packaging imported with
inbound goods, etc. For each, determine who is the brand owner and who the end
user is, to identify if it is household vs non-household waste.
For example, a manufacturing company might list: “Retail product
box – our brand – household”, “Outer shipping carton – used B2B
to retailer – non-household”, “Pallet wrap – we apply for delivery to
retailers – non-household”, “Pallets – we rent, eventually households
don’t see them – non-household”, “Component packaging from
supplier X – we discard – non-household (we’re the importer)”. This
exercise clari昀椀es what data you need and reveals any areas where
coordination with partners is needed (e.g. asking suppliers or clients
for info). If you are a logistics provider or contract packer, map out
packaging you use on behalf of each client, and ensure contracts
specify who will report those amounts.
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