Final Word: Extended Producer Responsibility

There are significant changes to packaging waste regulations coming in 2024 that will have considerable implications for wholesalers.

Here, FWD explains what is involved and how you’ll be affected.

What is Extended Producer Responsibility and why is it a big deal?

Extended Producer Responsibility (EPR), which comes into force next year, is the most significant change to the UK’s packaging waste regulations since their introduction in 1997. These changes will bring new financial and administrative burdens to businesses placing packaging on the UK market, which includes wholesalers. In fact, any business with an annual turnover of £1 million or more that is responsible for more than 25 tonnes of packaging in a calendar year will be eligible – this captures much of the FWD membership.

What will wholesalers need to do?

Collect and report data on the packaging you handle and supply, and pay a fee for packaging in scope. Only packaging that will end up in household waste will be obligated under EPR. That includes multipack wraps, branded labels and non-branded cans, but not secondary or tertiary packaging, such as shrink wrap.

So wholesalers supplying business to business will be largely exempt from most of these obligations?

Any secondary or tertiary packaging declared as non-household will not incur EPR fees, just the Packing Recovery Notes fee, as is the case now. But wholesalers will have to pay additional fees for any primary packaging supplied to another business that is not the end user of that packaging (for example, a foodservice outlet), even if the end user is a business and the packaging never becomes household waste, unless evidence can be produced to demonstrate it is commercial waste.

Why is that?

Because if any of the primary packaging ends up in household waste, all sales to that business are seen in that way. For example, if a wholesaler supplies a restaurant that sells most wine by the glass and disposes of its waste commercially but occasionally sells wine by the bottle for someone to take home, all wine bottles sold are classified as household waste. And evidence that distinguishes which item sold is going to be in commercial waste will be very difficult to produce for wholesalers.

Is it going to cost money?

If wholesalers are deemed to be supplying packaging that ends up in household waste, then the financial impact to their business will be significant, yes. The key is allowing wholesalers to report packaging as non-household on the grounds that it’s being supplied to business end users and, therefore, is not household waste. We’re working with Defra to make the case for the easiest possible reporting and minimal cost implications for our members.

ANALYSIS extended producer responsibility FWD packaging