BUSINESS READINESS FORUM - Q&A 

Questions & Answers

Please find answers below to the questions asked at the Business Readiness Forum on Tuesday 10 January. 

Question. When are we going to have sight of the base fees for the 2024 payments and then furthermore, the modulated fee structure that's going to be implemented for the 2024 data for payment in 2025?

Answer. We are aiming to provide an indication of base fees for the 2024 payments shortly. We will provide more details on our approach to modulating fees in the Summer of 2023.

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Question. Is it right that an obligated distributor needs to report on all packaging? If so, how are we expected to do that?

Answer. In terms of knowing who the de minimis producers are, packaging suppliers ("distributors" in the regulations) should assume all packaging they supply is obligated, unless they can evidence that they supply packaging to obligated producers.

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Question. Are there anymore updates on how we might be able to prove that primary packaging is non household waste when it goes to business waste? Or is it just the case that all primary packaging will now be obligated?

Answer. There will be guidance released shortly from the regulators around household packaging and how you can differentiate what household packaging is and what evidence you need for non-household packaging.

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Question. Is there an update on the appointment of the scheme administrator?

Answer. We expect that the Scheme Administrator will be appointed at the end of 2023.

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Question. Are there Northern Ireland representatives within that Sprint as well?

Answer. Representatives from all of the different devolved nations will attend the Sprints. We also have trade associations and Local authorities from all the different nations attending.

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Question. When will Defra publish the response to the CPR consultations?

Answer. We will be publishing the Government Response to the Deposit Return Scheme Consultation later this month. We will dedicate a Business Readiness Forum to this consultation and share details via the newsletter.

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Question. Is there a link where we can find all the guidance documents and summaries published to date?

Answer. All our guidance for EPR for packaging is available on gov.uk. Please see:

• Obligation Checker Tool: Check if you need to report packaging data
• Demonstration of: Obligation Checker
• Guidance: Packaging waste: prepare for extended producer responsibility
• Guidance: How to collect your packaging data for EPR
• YouTube presentations: Extended Producer Responsibility (EPR) – January 2023 requirements

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Question. Will more specific and much more detailed guidance be published regarding EPR packaging definitions e.g. "street waste"

Answer. See Packaging waste: prepare for extended producer responsibility - GOV.UK (www.gov.uk). This will be covered in greater detail in the Data Definitions and Reporting webinar. 

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Question. Can the obligation checker be embedded on other websites?

Answer. It cannot be embedded in another website, however it will be possible to link directly to the obligation checker on GOV.UK. 

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Question. Why can't data for EPR be captured with data for UK PPT to avoid duplication of data reporting?

Answer. This legislation requires much more data than the packaging sector has ever had to supply. In 2022 HMRC introduced the Plastic Packaging Tax, and this year Defra is bringing in new data reporting requirements as part of packaging Extended Producer Responsibility. EPR reporting is not able to be linked with UK PPT reporting because they are two separate obligations with different data reporting requirements for different purposes.

Further guidance on the Plastic Packaging Tax can be found on gov.uk: Plastic Packaging Tax - GOV.UK .

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Question. Please can you provide a link to the definition of nation data and exactly what data obligated companies need to report for this

Answer. Nation data is information about which country in the UK your packaging has been sold, hired, loaned, gifted or discarded in. See: How to collect your packaging data for extended producer responsibility - GOV.UK (www.gov.uk)

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Question. How do manufacturers categorise products which could be sold to end consumer, wholesaler and/or within catering environment, which all lead to household, non-household or even street litter?

Answer. In addition to the obligation checker, there is guidance available on GOV.UK how to prepare, and what data needs to be collected. These set out timelines for when different activities happen and who has to do what. If you use the obligation checker and it tells you that you are obligated, it will direct you to these guidance pages as applicable for support on next steps.  This guidance is available at:

Packaging waste: prepare for extended producer responsibility

How to collect your packaging data for extended producer responsibility

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Question. I was on the understanding it started Jan 2023 and was to be mandatory from March 2023.

Answer. If you are affected by the new EPR for packaging, we ask you to start collecting the correct packaging data from 1 January 2023.

Please note:

• Collecting this data won’t be mandatory until March 2023
• If you are a large producer, you will need to start reporting this data between July and October 2023.
• If you are a small producer, you will be able to report this data between January and April 2024

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Question. Will you put on further information sessions to introduce EPR?

Answer. Webinars were run in 2022 detailing EPR responsibilities.

Please see: Extended Producer Responsibilities (EPR) - January 2023 Requirements Webinar - YouTube .

We will be delivering further EPR sessions soon. 

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Question. My understanding is that Northern Ireland are not actually included in the data collecting regulations, and therefore presumably they're under no obligation to collect data until some form of regulation is put out in Northern Ireland on this. Is that correct?

Answer. Northern Ireland will be publishing a data collection regulation shortly.

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Question. With no Northern Ireland Assembly how is the legislation to be brought forward?

Answer. The legislation required for packaging EPR and Deposit Return Scheme can still be made in absence of a NI Executive. 

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Question. Can I clarify the position for Scottish producers are they obligated at the same time scales as England?

Answer. Yes, EPR is a four nation, UK wide approach.

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Question. Will the DRS scheme be the same as in Scotland? Are discussions taking place with Scotland so there is uniformity throughout the UK?

Answer. A separate Deposit Return Scheme (DRS) is being delivered in Scotland. We remain in close contact with officials and industry to learn from the Scottish scheme. 

Please attend the DRS focussed session at the next Business Readiness Forum on 24 January for more information.

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