Packaging EPR Obligation in the UK: A Guide for Amazon Sellers

New UK packaging EPR obligation. The obligation to pay the EPR fee is postponed.

In the ever-evolving landscape of environmental regulations, the United Kingdom has taken a significant step forward with the introduction of the Packaging Waste Regulations 2023. This regulation is effective from the year 2023, and it involves a reporting obligation, while the payment obligation has been postponed, so producers will not have to pay packaging EPR fees in 2024.

Understanding the Scope of Packaging EPR

Packaging is defined by the Packaging Waste Regulations as any material used to cover or safeguard goods sold to consumers. This includes materials facilitating easier and safer handling and delivery, as well as empty packaging, such as disposable coffee cups.

Have a look at our EPR article, including the French and German EPR schemes.

Identifying as a Producer for UK Packaging EPR

Determining whether one qualifies as a producer involves engaging in activities such as supplying goods under one's brand, handling unbranded packaging, importing products in packaging, owning an online store, or providing reusable packaging. Meeting these conditions confirms your status as a producer and entails compliance with the Packaging Waste Regulations.

In essence, if your product involves any form of packaging, it falls under these regulations.

  • Obligations for Non-UK Amazon Sellers: For sellers operating and selling goods subject to packaging EPR in the UK market via Amazon, but not established in the UK, compliance with these regulations involves automatic enrollment in Amazon's Pay on Behalf service, commencing in 2023. This service manages the reporting of sales data and facilitates payment of eco-contributions to relevant agencies and producer responsibility organizations (PROs) designated by Amazon.
  • Responsibilities for UK-based Amazon Sellers: UK-based sellers must comply with packaging EPR obligations. These obligations vary depending on whether the business is considered a small or large company.

If you are a non-established supplier meeting the producer criteria and not selling via Amazon, you must directly comply with your packaging EPR obligations. 

Some of the responsibilities that involve being a packaging EPR producer in the UK include:

  • Collect and report data on the packaging you supply or import.
  • Pay a waste management fee.
  • Pay scheme administrator costs.
  • Pay a fee to the environmental regulator.
  • Get packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) concerning your recycling obligations.
  • Report information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in – this is called ‘nation data’.

Have a look at the official HMRC information about packaging EPR.

UK was one of the first European countries to introduce plastic tax. Have a look at our article about UK plastic tax.

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