

Simple EPR
21 Aug 2024
Defra releases ‘Illustrative’ levies for base materials under EPR.
Defra has recently announced the first set of ‘illustrative’ fees for EPR, giving low, medium, and high fees for each material. These fees give guidance for the prices that will be incurred by obligated large producers under EPR.
Obligated producers are required to submit data under EPR every six months, and these fees will be applied to all obligated household packaging starting in October 2025 based on data submitted for calendar year 2024.
These fees will be charged in addition to PRN costs, which will be required for both household and non-household packaging, meaning producers of household packaging will have to pay both costs. PRN fees are not set centrally but are based on market rates, the costs charged by reprocessors and paid by producers and compliance schemes.
As these costs are estimates, Defra have given three fees for each material, Covering ‘Low’, ‘Intermediate’, and ‘High’ Scenarios. The table below shows these fees.

Since EPR was announced, Producers have struggled with having to comply with the regulations and submit figures without understanding how the submitted figures would impact on their budget, so this new information will be welcomed. Defra have warned against relying too heavily on these figures with the following statement.
“Government recognises that obligated producers may wish to use the higher or lower estimates to assess worst and best case scenarios. This is not recommended.”
Despite this warning, many producers will have little other information available to help them to predict costs and so reliance on these figures may become unavoidable.