Understanding the Implications of Extended Producer Responsibility (EPR)

Extended Producer Responsibility (EPR) is a policy approach being implemented across the UK and Europe to improve the sustainability of packaging by making producers responsible for the environmental impact of their products throughout their lifecycle. For businesses involved in print management, commercial printing, packaging, and promotional merchandise — including marketing agencies that buy and sell printed goods — EPR introduces new regulatory and operational considerations.

This paper outlines the core elements of the EPR framework, how it applies to key stakeholders in the print and marketing supply chain, and practical steps that can be taken to prepare for compliance while identifying opportunities to strengthen environmental performance and client value.

1. Introduction to EPR

Extended Producer Responsibility is designed to encourage more sustainable packaging design and shift the financial and administrative burden of waste management from local authorities to the businesses that place packaging onto the market. In the UK, the EPR scheme is being introduced in phases between 2024 and 2026.

The policy framework requires obligated producers to report data on the packaging they supply, pay fees based on the recyclability and volume of materials used, and contribute to the cost of waste collection and recycling services.

For organisations operating within the print and marketing supply chain, EPR has implications across procurement, design, production, and data management functions.

2. Who is Affected?

The EPR policy applies to businesses that meet the following criteria:

• An annual turnover of more than £1 million
• Handling or supplying more than 25 tonnes of packaging per year

Within this threshold, the definition of a “producer” under the regulations can include:

• Print Management Agencies (PMAs) that coordinate the design, sourcing, and distribution of printed packaging or merchandise on behalf of clients
• Printers that supply packaging directly to end users or import printed goods
• Marketing and Creative Agencies that procure or import branded merchandise and packaging
• Brand Owners or Retailers whose identity appears on packaging or the product

Defining a ‘Producer’ under EPR

Under the UK’s Extended Producer Responsibility regulations, the term “producer” is not limited to manufacturers. Instead, it encompasses a range of business activities that involve placing packaging or packaged goods onto the UK market. This is particularly important in the context of print, packaging, and promotional merchandise, where responsibility can fall to various points in the supply chain.

A business may be classed as a producer under EPR if it performs any of the following roles:

• Brand Owner: A business that sells packaged goods or printed materials under its own brand. If your company name or logo appears on the product or its packaging, you are typically considered the producer.
• Packer/Filler: A business that puts goods into packaging, regardless of who manufactures it. This includes marketing campaigns that involve assembling printed kits, POS materials, or merchandise into packaged sets.
• Importer: A business that brings packaged goods, printed materials, or promotional merchandise into the UK from abroad. The importer is responsible for EPR obligations if the overseas supplier does not have a UK presence.
• Distributor: A business that supplies packaged goods to third parties in the UK (e.g. wholesalers or B2B providers) may carry producer responsibilities if acting as the first supplier within the market.
• Online Marketplace Operator: Digital platforms facilitating the sale of packaged goods or promotional products from third-party sellers to UK consumers are also considered producers under the scheme.

In cases where more than one organisation in a supply chain could be classed as the producer, the EPR regulations specify a hierarchy of responsibility. Typically, the business that first places the packaging on the UK market, or has legal ownership of the goods when they enter the country, is the obligated party.

This broad definition means that marketing agencies, print management firms, printers, and merchandise suppliers may all fall under EPR requirements, even if they are not the original manufacturers of the packaging or products involved.

3. Core Requirements of EPR

a. Packaging Data Collection and Reporting

From 2024, obligated businesses must gather and report detailed data about the packaging materials they supply. Required data includes:

• Type and weight of material (e.g. paperboard, flexible plastic, glass)
• Packaging format (e.g. box, label, mailer, envelope)
• Whether the packaging is household, non-household, or both
• Geographic destination (England, Scotland, Wales, Northern Ireland)
• Recyclability status

Businesses must submit this data biannually via the Environment Agency’s reporting platform. While initial reporting does not yet carry direct costs, the data will inform the calculation of future EPR fees.

b. Financial Contributions to Recycling Costs

From 2025, producers will begin paying fees to cover the cost of managing packaging waste through the public recycling system. These fees will be modulated — meaning they vary depending on the recyclability of materials used and whether they meet certain eco-design standards.

Materials that are harder to recycle or are commonly landfilled (e.g. composite plastic-paper laminates) may incur higher fees. This could influence decisions around material choices and packaging formats for print and merchandise.

c. Encouragement of Sustainable Design

A key goal of EPR is to incentivise the design of packaging that is easier to recycle or reuse. While this is not a legal requirement, producers that demonstrate the use of recyclable or recycled materials and minimise unnecessary packaging may benefit from lower fees and improved client perception.

4. Key Considerations for the Print and Marketing Sector

a. Clarifying Responsibility Across the Supply Chain

Given the complex and often multi-tiered nature of print and marketing supply chains, it is important to establish who holds legal responsibility for packaging data and fee payments.

Agencies and PMAs should review their contracts with clients and suppliers to determine:

• Who is acting as the producer under EPR definitions
• Who is responsible for collecting and submitting data
• Who will bear any associated fees or penalties

Where multiple parties are involved in the creation or import of packaging, clear roles and responsibilities should be agreed and documented.

b. Data Capture and Material Traceability

To comply with EPR requirements, organisations must improve visibility into the materials used in packaging and printed goods. This includes:

• Maintaining records of weights and material types
• Verifying recyclability status with suppliers
• Capturing data for imported promotional items or mail packs

Suppliers may need to provide detailed breakdowns of component materials, especially for packaging that contains multiple substrates or finishes.

c. Technology, Systems and Reporting

Many businesses will need to adapt their internal systems to manage EPR data collection and reporting. This may include updates to:

• MIS or ERP systems
• Procurement and job management workflows
• Supplier declaration forms and onboarding processes

It is also advisable to assign internal responsibility for EPR compliance and ensure appropriate training for staff involved in procurement, production, or client service.

5. Potential Strategic Impacts

While EPR introduces new administrative requirements, it also aligns with broader trends toward sustainable procurement and corporate environmental responsibility. For businesses in the print and marketing sector, this shift presents both risks and opportunities.

Opportunities

• Enhanced Service Offerings: Agencies and printers that can support clients with EPR compliance — including data reporting, material selection, and packaging optimisation — may become more valuable supply chain partners.
• Sustainable Innovation: Investing in more recyclable substrates, minimising over-packaging, and avoiding problematic materials (e.g., black plastic, glitter) may support brand goals and client retention.
• Reputational Benefit: Demonstrating proactive compliance and a commitment to sustainability may support wider ESG strategies and enhance competitiveness in tenders.

Risks

• Increased Costs: Non-recyclable or composite packaging formats may become more expensive to produce due to higher modulated fees.
• Contractual Ambiguity: Without clear terms, disputes may arise over who is responsible for data and fees in complex supply chains.
• Operational Disruption: Lack of preparation could result in non-compliance, late reporting, or reputational damage.

6. Practical Steps for Preparedness

To prepare for the full implementation of EPR, organisations should consider the following actions:

1. Assess Your Status: Determine whether your organisation meets the reporting threshold and whether you qualify as a producer under EPR rules.
2. Map Your Packaging Footprint: Audit packaging formats, materials, and suppliers to understand where your obligations lie.
3. Engage Suppliers: Begin discussions to ensure upstream data on packaging materials and recyclability can be provided accurately and consistently.
4. Update Internal Processes: Establish data collection and reporting procedures, assign responsibilities, and update contracts to reflect new obligations.
5. Explore Sustainable Alternatives: Review packaging and merchandise formats to identify opportunities to shift towards more recyclable or modular designs.

7. Conclusion

EPR represents a significant evolution in packaging regulation that will affect many organisations in the print, packaging, and marketing sectors. While the requirements are detailed and still evolving, early action to improve material traceability, clarify responsibilities, and support clients in sustainable design can help businesses remain compliant, minimise risk, and strengthen market competitiveness.

By approaching EPR not only as a compliance challenge but as a catalyst for operational and environmental improvement, businesses across the print and marketing value chain can play a constructive role in the transition to a more circular economy.

Further Resources and Information on EPR:

UK Government Guidance on Extended Producer Responsibility for Packaging

This official guidance outlines who is affected by EPR regulations in the UK, detailing reporting requirements, fee structures, and compliance deadlines. It is essential for businesses seeking to understand their obligations under the new packaging waste regulations: https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do

WRAP (Waste and Resources Action Programme) – EPR Policy and Insights

WRAP provides comprehensive resources on EPR, including policy insights, recent projects, and news updates. Their materials are valuable for understanding the broader context of EPR and its implementation in the UK: https://www.wrap.ngo/what-we-do/our-services/policy-and-insights/extended-producer-responsibility-EPR

Chartered Institution of Wastes Management (CIWM) – EPR Reports and Research

CIWM offers in-depth reports and research on EPR and related waste management topics. Their resources are beneficial for professionals seeking detailed analyses and sector-specific information: https://www.ciwm.co.uk/ciwm/news-and-insight/reports-and-research.aspx

The Recycling Association – EPR Information and Updates

The Recycling Association provides news and commentary on EPR developments, focusing on the recycling industry’s perspective. Their insights are useful for understanding the practical implications of EPR policies: https://www.therecyclingassociation.com/extended-producer-responsibility