EPR Guide - Flipbook - Page 29
7. Internal Roles & Responsibilities
EPR compliance isn’t just an environment team issue; it touches multiple departments:
• Operations/Production: They have the data on packaging usage. Ensure production managers
or logistics managers are recording how much packaging is used or shipped. Set up SOPs to weigh
and log packaging.
• Procurement & Packaging Design: They should prioritize purchasing recyclable packaging and
liaise with suppliers to get material speci昀椀cations. Procurement can work with packaging vendors
to perhaps reduce packaging weight or switch to easier-to-recycle formats (which will save costs
long-term). They also need to demand that suppliers provide data on any packaging that comes
with inbound goods.
• Sustainability/Environmental Team: Often leads on reporting and ensuring all data is
collected. They should stay up-to-date with DEFRA guidance changes, manage the relationship
with compliance schemes or the regulator, and spearhead internal education about EPR.
• IT/Data Management: If possible, integrate data collection into your systems. Some companies
have updated ERP software or built databases for packaging data. This reduces manual effort and
errors.
• Finance: Must handle fee payments and incorporate them into pricing/forecasting. Finance or
commercial teams may also need to update customer contracts, e.g. some B2B contracts now
include clauses to adjust prices if packaging fees increase, or to clarify which party covers the EPR
cost (especially relevant for contract manufacturing or logistics arrangements).
• Marketing/Sales: They might wonder why they’re involved, but EPR has customer-facing
implications. Marketing Teams should know what claims they can make (e.g. “100% recyclable
packaging”, which not only is a sustainability claim, but also would imply lower EPR fees). Sales
Teams should understand EPR costs when negotiating deals (particularly if customers push back
on price increases due to “that new packaging tax”).
It’s wise to create a cross-functional EPR task force or designate an EPR Compliance Lead who
coordinates all these inputs, at least in the initial years as processes stabilize.
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