With UK businesses facing a tsunami of EPR policy reform in the coming months, Biffa’s Harriet Martin and Carla Brian explain why it is so important not to get left behind.

The influx of rules, regulations and policies surrounding packaging and waste can be a little overwhelming for those not fully versed in the legislation language.

From the already live Plastic Packaging Tax and the imminent Simpler Recycling for businesses to impending policies such as Deposit Return Scheme, and packaging Extended Producer Responsibility (pEPR), it is most definitely time for retailers to step up their sustainability know-how.

The new rules aim to inspire a more circular economy for packaging by creating accountability for materials used. The incoming regulations will also encourage brands to think more sustainably about the lifecycle of their packaging post-purchase.

And while retailers have got their work cut out to ensure they are adhering to all the new stipulations, those who are on the front foot could come out with a boosted reputation.

The perks of being a pioneer

Early adopters will be able to capitalise on the brand perception and commercial opportunity of being a sustainable leader. The data that producers gather has value way beyond compliance.

EPR sets the stage for a national overhaul of the packaging industry, but data gathering is the first and most important step in getting the policy off to a strong start.

All businesses obligated under EPR need to submit their data in two phases. The 2024 data involves reporting data from January to June, starting on July 1, 2024. The second phase requires reporting data from July to December, starting on January 1, 2025.

EPR reporting obligations are dependent on business size, so larger producers have now submitted their 2023 data, while smaller producers are required to report the full year for the first time from January 2024.

EPR will change packaging in the UK in ways that extend beyond data collection. How we act on that data will be crucial to successfully realising a UK circular economy.

The process of transformation and progress provides rich storytelling for shareholders, customers and colleagues.

Tell me more about pEPR

pEPR is a policy which holds producers responsible for the collection, sorting, recycling, or disposal of their product packaging. The policy is due to be introduced in 2025, with producers required to report their packaging data from 2023.

UK businesses who handle packaging will need to fund the total cost of managing packaging waste (from production to removal) in addition to their current liability.

This means paying for all packaging they introduce to the UK market, plus additional fees for waste disposed of by household consumers.

For example, a baked beans manufacturer must cover the costs of the pallet and shrink wrap used to send its beans safely to the supermarket, plus additional household fees for its own brand tins its customers recycle at end of life.


Harriet Martin is policy and regulation manager at Biffa.

Carla Brian is head of project partnerships at Biffa.

Biffa is providing expert support to businesses of all sizes through waste policy reform. Click here for more information.