Extended Producer Responsibility (EPR) legislation was first introduced in 2021. Over the last three years, changes have occurred that beauty businesses must be aware of – here’s everything you need to know ahead of 2025
In the Autumn of this year, the Government announced several key changes to the current EPR legislation. Below, we have highlighted the most important changes to the regulations and what they may mean for UK businesses.
The Following Changes were Announced in the Government’s 2024 Autumn Budget:
- Increase to Plastic Packaging Tax in 2025-6, in line with Consumer Price Index (CPI).
From April 1, 2025, the new Plastic Packaging Tax (PPT) rate will increase from £217.85 to £223.69 per tonne. This will apply to UK-imported and manufactured packaging that contains less than 30% plastic.
- Businesses can use a ‘mass balance approach’ to chemically recycled plastic for Plastic Packaging Tax.
A mass-balance approach to chemical recycling allows businesses to utilise recycled packaging more efficiently.
The approach involves tracking recycled content throughout the production process rather than simply calculating recycled content at the end of production.
Because overall recycled content is tracked throughout the production process, the final product can claim a higher percentage of recycled content than it contains. The mass total of recycled content found in the entire production chain accounts for any changes in the recycled content of individual packaging.
Businesses should note, however, that the government has confirmed that ‘pre-consumer waste will no longer be classified as recycled plastic for the purpose of PPT.’
Other things you need to be aware of:
- From February 2025, both PRNs/PERNs will be visible and available on a new digital service, highlighting the importance of remaining informed on the new EPR scheme.
DEFRA recommends that packaging be assessed using Recyclability Assessment Methodology (RAM) as early as possible to highlight and prevent data gaps. More information on RAM and DEFRA’s guidance can be found here: https://consult.defra.gov.uk/extended-producer-responsibility/extended-producer-responsibility-for-packaging/user_uploads/4.-modulated-fees-and-labelling.pdf.
Producers should also remember that packaging waste recycling notes (PRNs/PERNs) from December 2024 can be used towards 2024 or 2025 obligations. Packaging Recovery Notes (PRNs) are certificates that provide evidence that packaging has been sent for recycling. Packaging Export Recovery Notes (PERNs) serve the same function regarding packaging exported outside the UK for recycling.
- Businesses should be aware that the deadline for reporting EPR data for January- June 2024 has passed, and data from July- December 2024 is due by April 2025.
Simpler recycling regulation exemptions:
Finally, business owners should note that some exemptions to the Simpler Recycling Scheme may apply to them. The scheme was designed to introduce a uniform approach to recycling across the UK.
The scheme’s goal is to improve recycling rates in businesses and individuals by reducing the number of bins required and clarifying any confusion over what can and can’t be recycled.
The key change to this regulation relates to businesses that can be classified as ‘micro-firms,’ that is, those with less than ten employees. For these businesses, an exemption to the Simpler Recycling scheme will apply until 31 March 2027.
However, for larger businesses, primary legislation for the Simpler Recycling scheme has now been implemented and will apply to all workplaces and households in England.
