Completing your first bi-annual packaging data submission

The final submission under the previous 2007 packaging regulations was completed in April and we are well underway with preparations for the first bi-annual EPR submission opening in July 2023.

Completing your first bi-annual packaging data submission

Large organisations (that meet or exceed an annual turnover of £2 million and 50t of packaging supplied per calendar year) are required to submit packaging data bi-annually from 1 July 2023. When assessing whether you are classed as a small or large organisation under EPR, you will need to assess the packaging your business supplied in 2022 under the new points of obligation/ producer activities under EPR.

• 2 July 2023: Beyondly’s packaging data submission portal opens for the first bi-annual packaging data submission for large organisations. This should include data on obligated packaging supplied to the UK market from 1 January 2023 to 30 June 2023.
• 15 August 2023: Beyondly internal deadline for the first bi-annual submission. Our Packaging team will be on hand to support with your submission and will conduct verification checks on the data you submit, raising any queries with you.
• 16 August 2023: Government online portal opens for obligated organisations to enrol with the regulator. Enrol with business information and select you are a member of Beyondly compliance scheme.
• 1 October 2023: Following data verification checks, the packaging data of all our large organisation members shall be submitted to the regulator (EA) by the regulator deadline.

Government published the packaging data submission specification for EPR packaging data submissions in late March 2023. This outlined how the regulator expects packaging data to be submitted by direct registrants and compliance schemes. It is then at the discretion of each compliance scheme to design their submission portal and process, to collect this data from their members. Beyondly’s submission portal is still being finalised; part 2 of our EPR transition year (2023) submission support webinar series gives a preview of this and we shall communicate further guidance on completing your submission via our portal as soon as we can.

In the meantime, the government packaging data submission specification outlines the categories you are required to apply to your obligated packaging, please click here.

In preparation for the first bi-annual submission, we have hosted a 3-part webinar series on data collection, data submission and preparing for future EPR requirements, which you can access from your member portal. 

DEFRA are also keen to gauge the readiness of organisations for EPR, so please fill out their survey here by 16 June as honestly as you can!

Environment Agency (EA) confirm further EPR details

Several operational details have been confirmed by the EA ahead of the first bi-annual submission:

• Obligated organisations will be required to enrol with the regulator (EA) themselves. This cannot be conducted on your behalf by us as your compliance scheme. For large organisations enrolment opens 16 August 2023, for small organisations enrolment opens 1 January 2024. Enrolment must be completed by an approved person, which is a company director or company secretary listed on Companies House. Delegated authority can be approved by the EA.
• Approved person (company director or company secretary) sign off of the data will be required after both bi-annual submissions for large organisations.
• Exported packaging does not need to be included in your packaging data submissions, as this is not supplied to UK market and does not enter the UK’s waste stream.
• For packaging declared under the new material category of fibre-based composites, paper PRNs are to be procured to offset obligations.
• Data collection and submission records must be retained by obligated organisations for 7 years (compared to 4 years in previous regulations).
• Packaging in scope of Scotland’s Deposit Return Scheme (DRS) that was due to go live in August 2023 but has since been delayed until October 2025 is not to be included in packaging data submissions and will not attract a packaging compliance obligation during 2023. This cannot be amended as it is written into the 2023 data reporting regulations.
• Beyondly, as your compliance scheme, will have no involvement in the EPR waste management fees calculated and raised on household packaging from April 2024. Beyondly will submit your packaging data to the regulator (EA), who will then supply your obligated packaging total to the Scheme Administrator to calculate and raise EPR waste management fee invoices directly with obligated organisations.

Guidance

Please find linked below some useful resources from Government and the Environment Agency (EA) in preparation for EPR:

• Packaging EPR: who is affected and what to do click here
• Packaging data: what to collect for EPR click here
• Packaging data: how to create your file for EPR click here
• EA’s Technical interpretations and agreed positions for EPR click here and view the document titled “pEPR agreed positions v1.0”
• DEFRA webinar on EPR & PRN systems click here
• DEFRA webinar on household and non-household packaging definitions click here
• DEFRA webinar on the new nation data reporting requirement click here
• DEFRA webinar on DRS for drinks containers in England, Wales, Northern Ireland click here
• Subscribe to DEFRA’s EPR reform newsletter here

Please get in touch with your account manager or the Packaging team on packaging@beyond.ly with any questions. Thank you for reading and keeping up to date with packaging policy developments! 

Emma

Regulatory Affairs Leader

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