Regulation

Change

Explanation

Brand Owner

Supplied under your brand

A company, based in the UK that is part of a group, supplies branded packaging where the brand is owned by a non-UK member of the group will now have to report that packaging as Brand Owner.

A producer that imports packaging containing the brand of their non-UK sister or parent company, would now report that packaging under the activity ‘Supplied under your own Brand’ compared to ‘Imported’ previously.

Pack/Filler

A reiteration from the regulators that altering packaging for reuse, such as shredding boxes for use as filler, is a recycling activity and any ‘new material’ should be reported as such.

A producer imports a filled cardboard box which they empty upon import, shred, and reuse. This material would be obligated once as ‘Imported’ and again as ‘Packed or Filled’ when used as shredded card. (Brand Owner regulations apply where necessary).

Supplied as Empty [to companies below the threshold?]

There are new data gathering requirements for companies that supply empty packaging to large producers.

This is a data gathering requirement only, and does not need to be reported to Beyondly or the EA.

This does not include packaging supplied to large producers who are only ‘sellers’ and no other class of producer.

A producer (“D”) who supplies unfilled packaging to a large producer will have to collect the following data:

1. The identity of said large producer
2. That producer’s ‘producer registration number’ (only necessary for supply that takes place after 1 Oct 2025)
3. The number of units of packaging that D supplied to said large producer in the reporting period

The weight of both household and non-household packaging supplied to said large producer in the reporting period.

Tertiary and Shipment Packaging

Following feedback over the previous reporting periods, there has been a change to the definitions of Tertiary and Shipment packaging.

Tertiary Packaging is conceived to facilitate the handling and transport of one or more sales units, or secondary packaging, to a business, for example preventing damage during handling or transport.

Shipment Packaging is tertiary packaging on, or containing, items intended to be supplied to a consumer.

Drinks Containers

The lower limit of what constitutes a drinks container has been increased from 50ml to 150ml.

Therefore, containers between 150ml – 3L should be reported as ‘Drinks Containers’.

Drinks Containers

Labels applied to glass drinks containers, along with lids or other closures, should now be reported separately under the packaging type ‘drinks containers.

This does not affect drinks containers made of materials other than glass, where the whole drinks container should be reported under the majority material by weight.

Reusable Packaging

A reminder that where a producer has a system for recording ‘reusable packaging,’ that a suitable methodology and description of that system should be recorded.

This is a data gathering requirement only, and does not need to be reported to Beyondly or the EA.

An example could be that a producer imports goods on pallets which are taken down and stored for on site for reuse, or how packaging returns from business customers for reuse are calculated.

Self-managed Consumer Waste

For packaging collected from consumers and included in a submission to offset disposal fee costs, evidence should be stored to show that recycling has taken place.

As packaging collected from consumers and sent for recycling can be used to offset disposal fees and can often be tricky to recycle material that is not included in kerbside collections, evidence should be stored to show that the material was recycled.

Self-managed Organisation Waste

A reiteration from the regulators that any waste packaging sent for recycling should be included in submissions.

And that any packaging added to facilitate the transport of waste (such as bailing wire) should be recorded under the activity ‘packed or filled’ where appropriate.

Record Keeping Obligations

And finally, a reminder that all records relating to pEPR data gathering obligations, including the Recyclability Assessment Methodology (RAM) should be kept for at least 7 years from the period to which the data relates to.

Recyclability Assessment Methodology (RAM)

To be completed on your 2025 packaging placed on market.

Simpler Recycling for businesses

By 31 March 2025, all businesses in England, with more than 10 employees, will be required to recycle the following at all their workplaces

• Food Waste
• Plastic, Glass, and Metal
• Paper and Card

Businesses with less than 10 employees, and flexible plastics are delayed until 31 March 2027

Obligation to report data on plastic or paper bags supplied in England

A report of the number of single use, plastic and paper carrier bags supplied in England starting with your 2025 packaging placed on market (we are awaiting further clarification on this before we release more information).

Appointment of the Deposit Management Organisation in relation to the DRS

The current roadmap from the government is that a DMO will be appointed around April 2025 to run the DRS, which should lay the plans for DRS in the run up to 2027.