Extended Producer Responsibility for packaging waste – sellers' responsibilities

Since 1 January 2023, suppliers of packaging and packaged products to end users must collect information on the quantities supplied to the UK market throughout a calendar year. One of the annual reporting requirements is specifying which UK nation this packaging is sold into.

The first report is due by 1 December 2025 for packaging supplied across 2024.

This requirement also applies to importers of packaging and packaged goods, businesses that supply empty packaging to exempt producers, online marketplace operators, and businesses which lease out packaging for others to use for their activities.

This reporting requirement is in addition to the data reporting and financial obligations an obligated producer could incur due to other activities they perform*.

Businesses that supply packaging in the UK in any of the above ways need to consider that:

• They will need to capture data in much finer detail than under the current Packaging Waste Regulations
• Gathering the required data may well require liaising with suppliers and partners in your supply chain. It therefore may be prudent to contact these businesses early to establish the data you need from them and in what format
• The first report is due by 1 December 2025; however, there are earlier reporting deadlines for other producer types which you may need to submit data by

* Such as a brand owner or importer of packaged goods supplied onto the UK market. For further details about the obligations of producers under EPR, and to see if you could be obligated in this way, request a copy of our EPR for packaging white paper and take our EPR obligation test.

We have produced a summary of seller obligations for Valpak members. This is available in the EPR Hub section of our Members’ Area.

If you are affected, it is imperative to act now to ensure there is visibility of packaging material flows and of materials used within the business. It is also important to make yourself aware of which materials are cost and/or environmentally efficient, as doing so will help to ensure that additional costs to your business are kept to a minimum.

As the UK’s largest producer compliance scheme for packaging, we can provide the following services to help ensure your business is in the best possible position ahead of the implementation of this new legislation:

• Free EPR clinics
• Free, high-level cost implication assessment
• Detailed EPR assessment, including cost modelling and benchmarking
• Data collection service via Data Insights (where data is not sufficient)
• Data visibility via the Valpak Insight Platform
• Consultancy – A detailed look at assessment recommendations, end market research, and advice on the next steps

Our service is bespoke, which means we can offer as much or as little support as required. Contact us today!