How could EPR regulations affect skincare packaging?

The Current Packaging Waste Regulations are being replaced by the Extended Producer Responsibility which is bound to bring some changes to the cosmetics and skincare markets. So make sure you're aware of them...

The UK government committed to protecting the environment and have pledged to achieve net zero carbon emissions by 2050. EPR is succeeding the Producer Responsibility Packaging Regulation to place a greater responsibility on businesses for the full net cost of packaging at end of life.

How long has the EPR concept been around for?

The concept was first formally introduced in Sweden in a 1990 report stating that EPR is an environmental protection strategy to reach an environmental objective of a decreased total environmental impact of a product by making the manufacturer of the product responsible for the entire life cycle of the product and especially for the takeback, recycling and final disposal.

What is the implementation timescale for EPR?

EPR was due to have a phased implementation in 2023 but the implementation of fees to local authorities will now take place in October 2025. However, producers will be required to report packaging data for 2023 as planned. Large producers must enrol and submit data by 1st October 2023 for packaging handled from 1st January to 30th June 2023.

What are the key points?

With this new policy a number of changes have been imposed on companies, with the key changes being :

There will be new costs for businesses made up of two parts:

Current PRN (Packaging Recovery Notes) system covering the cost of recycling
Disposal costs

Instead of the previous shared obligations system, the whole obligation sits on one type of producer. As a result, you must identify which producer types(s) your business is responsible for:

Brand Owner – who package goods and sell them under their brand name. When a brand is not identifiable, the obligation falls to the organisation that carried out the packing or filling of the packaging.
Packer/Filler – a company who packs goods into packaging where there is no brand owner.
Importer – all filled packaging imported into the UK where there is no brand owner.
Distributor – any unfilled packaging supplied on to businesses which are not obligated producers.
Online Marketplace – Any packaging around goods sold from outside the UK through an online marketplace.
Service providers – who hire out or lend reusable packaging.

What might our customers have to do differently?

Customers will have to determine which producer category they fit:

Large producer - greater than 50 tonnes of waste and over £2m turnover, in which category you must assess packaging supplied and have full obligation. You must also report data twice per year and purchase PRN (Packaging Recovery Notes), and if household packaging is supplied, then disposal fees may apply.
Small producer – 25-50 tonnes, assess packaging supplied and report once per year.