Environmental information specialist Ecoveritas has warned companies to not be caught off-guard following the Setting Company’s announcement on 5 September that it’s delaying the enforcement of its Prolonged Producer Duty (EPR) information submission deadline.
Underneath the brand new edict, corporations that miss the primary two EPR submission deadlines of 1 October 2023 and 1 April 2024 is not going to be prosecuted, offered they submit all required information by 31 Might 2024. Nevertheless, the deadline for submission beneath the prevailing Producer Duty Obligations (Packaging Waste) Rules 2007 stays unchanged (7 April), including an additional layer of complexity to the dual-reporting transitional part of the EPR rollout.
Rebecca Webber, Operations Supervisor at Ecoveritas, warned companies to not take the extra time with no consideration, saying, “We encourage corporations to do their finest to fulfill their present deadlines. We can be working with all our shoppers carefully utilizing all affordable endeavours to report packaging information by the present reporting dates of 1 October 2023 and 1 April 2024, wherever doable, as we perceive that this packaging information is important to enhancing the modelling of illustrative base charges, which producers so desperately have to plan successfully for the long run. Defra can’t present producers with the indicative prices they urgently require with out this information.
The extra information producers can present Defra with, the extra correct the illustrative base charges can be. Producers can then count on to see first estimates by the tip of 2023/early 2024.
“It’s necessary to keep in mind that submitting beneath the outdated 2007 rules stays unchanged, so one-half of enterprise reporting stays the identical at the same time as the opposite half consistently shifts,” added Webber. “Clearly, the rollout of EPR continues to be an absolute omnishambles, however it’s companies who pays the value in the event that they get any particulars flawed in a last-minute scramble to fulfill the brand new Might deadline.”
Notably, this regulatory place assertion (RPS) doesn’t change the authorized requirement to report info on or earlier than 1 October 2023 and 1 April 2024. Nevertheless, the Setting Company is not going to usually take enforcement motion if H1 & H2 information is submitted by the tip of Might.
The RPS stays in pressure till 30 June 2024. Nevertheless, the Setting Company has warned it might “withdraw or amend” its place earlier than this date if deemed vital, which means there’s uncertainty over the prospect of deadlines shifting additional again – and even ahead – at comparatively brief discover.
“Frankly, it’s a multitude,” continued Webber. “This transition interval ought to signify the proper probability to construct up that muscle reminiscence for companies – to entrench enhanced information assortment as a core enterprise operation. However we regularly see that studying course of being undermined by delay, and now by neutering the enforcement course of.
“As we’re lower than a month away from the October deadline, we count on most companies to have an almost-complete submission able to go anyway. We might encourage them to do what the federal government seemingly can’t – lead by instance and attempt to make EPR work.”