Extended Producer Responsibility

Extended Producer Responsibility

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loosemarbles

Original Poster:

1,845 posts

205 months

Wednesday 19th July 2023
quotequote all
Is anyone else on here developing a headache when it comes to the new EPR reporting coming in?

We sell primary packaging, so obviously have reported previously on what we have imported, but the new reporting is quite something else. For us, the key thing is understanding for which sales we have a liability for. We have plenty of large customers, so we know that they have their own liability, but we have 400+ customers which don't buy 25t of packaging through us. DEFRA expect us to search manually for each single customer to determine whether they are liable, which isn't exactly feasible.

We can't contract out of the obligation (i.e. can't stipulate in our T&C that customers are liable, unless they tell us), but are there other ways?

Does someone like Experian allow a link to determine turnover of a company, but even then, many may be under the £1m revenue limit, but easily buying more than 25t of packaging.