EPR Guide - Flipbook - Page 28
5. Review Your Fee Invoice and Plan Payments
When you receive your Notice of Liability (likely each October), examine it: it will detail how much
you owe for each material, how it was calculated (tonnes x fee rate), and payment schedule options.
Reconcile it with your own data records to ensure there were no major discrepancies in what you
reported versus what was billed. If you believe there’s an error, raise it quickly with PackUK or your
compliance scheme.
Then, arrange payment. Decide whether to pay in full or opt for instalments if offered. Ensure your
昀椀nance team knows these invoices are coming – they can be multi-million for large 昀椀rms. Missing a
payment can trigger a Variable Monetary Penalty (VMP) by PackUK: at least 20% of the unpaid amount
or 5% of annual turnover (whichever is greater for a single company). These are steep 昀椀nes, so treat
EPR bills like tax obligations. PackUK will send a “notice of intent” 昀椀rst if you fail to pay, giving 28 days
to respond, and then a 昀椀nal penalty notice, if unresolved.
As part of this, adjust your budget forecasts. EPR fees are essentially a new operational cost, many
companies treat it as a cost of goods sold for packaged products. For instance, if packaging fees add
£0.005 per unit, you might decide to absorb or pass that on. We discuss cost strategies later, but from
a compliance view, make sure your organization allocates funds for EPR fees each year.
6. Obtain Recycling Evidence (PRNs/PERNs)
If you’re a large producer, you must continue to meet recycling targets by obtaining suf昀椀cient PRNs/
PERNs annually until told otherwise by law. Compliance schemes typically handle this (they’ll buy
PRNs on your behalf proportional to your obligation). If you handle it directly, use the National
Packaging Waste Database to 昀椀nd accredited reprocessors/exporters and acquire PRNs equal to the
tonnages needed for each material category under the old rules. Keep certi昀椀cates as proof. Note: the
speci昀椀c recycling target percentages can change each year (e.g. X% of plastic, Y% of glass must be
“recovered”). For 2023–2024, these targets applied. The new EPR regime may streamline or modify
this obligation in future, but until of昀椀cially changed, do not neglect PRN compliance, the EA can 昀椀ne
companies that fail to meet it, separate from EPR fees.
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