BLOG: What is Extended Producer Responsibility (EPR) and how does it affect me as an exporter?

If you have your finger on the pulse regarding sustainability, you’ve likely heard of Extended Producer Responsibility (EPR) but may still be wondering how it affects you.

Quite simply, EPR is an environmental policy that makes producers responsible for the entire life cycle of the products that they introduce on the market, importantly, from their design right through until end of life (including waste collection and recycling). Under EPR regulations, liable companies must mitigate the environmental impacts of their products throughout the entire product life cycle.

If you export to other countries where this regulation is in force, you effectively become the ‘Producer’ and must ensure adherence to EPR obligations in that target country before it will allow you to place your products on its marketplace. So, where EPR regulation exists and where your business comes under the scope of EPR requirements, you have to contact the respective Producer Responsibility Organisation (PRO) for each EPR product category you export in order to obtain an EPR registration number.

The EU Commission is leading the way on this type of regulation; however, no two Member States have implemented the regulation in the same way, making it more onerous for UK companies exporting pan-Europe. Given the increased focus on sustainability and climate change, we envisage this trend continuing to evolve at quite a significant pace globally.

To understand whether you are impacted and need to comply, you must consult the PRO guidance in the export market. Compliance thresholds and recycling obligations vary but are based on established core data, so in most cases, you will need to know:

• The types of packaging you handled in the previous calendar year
• The volumes of packaging you handled in the previous calendar year
• What activities you performed on that packaging in the previous calendar year

Marketplaces like eBay, Amazon, Ankorstore, etc. are now being charged with collecting and validating EPR registration numbers and where companies cannot prove compliance, marketplaces will be obliged to suspend those non-compliant listings that fall under the relevant ERP product categories e.g. in Germany.

Certain intermediaries/facilitators have established themselves in light of this new regulation to enable companies to achieve pan-European compliance in exchange for a recurring management fee. Prominent ones are Ecosistant and Lizenzero.eu. NB: Global Trade Department has not evaluated these companies.

Regulatory compliancy can be a tricky and overwhelming subject, sometimes you simply don’t know what you don’t know. We’ve helped numerous clients in this area and with wider sustainability issues so don’t stress and subject yourself to rafts of regulation text. If you think you could be impacted by EPR and want to chat it through and understand what to do next, simply book a session with one of our specialists in our Global Trade Clinic (https://www.globaltradedept.com/global-trade-clinic/) and we will happily help. Advice is free, impartial, and confidential.

About the Empowering SMEs in International Trade programme:

Whether you are an exporter looking to expand your brand further overseas or a UK company looking to add resilience to your supply chain by exploring overseas providers; this fully funded programme will be invaluable in increasing your knowledge, limiting your risk, and ensuring success when dealing with international markets. For a full programme of upcoming events, past webinars, case studies, and more, go to https://www.globaltradedept.com/empowering-smes-in-international-trade/.

Andrea is an international trade specialist with 25+ years’ experience in the industry. A linguist fluent in French and Spanish, Andrea specializes in Importing, exporting, EU Exit preparedness, business resilience, and business growth. A passionate ambassador of UK micro businesses and SMEs, she launched the Global Trade Department (previously The Export Department) to assist these companies expand their horizons internationally and raise the profile of UK goods and services abroad. As well as supporting private clients with their international trade endeavours, Andrea delivers 1:1 support and 1:Many support for a number of Growth Hubs nationwide and is responsible for the design and delivery of a range of EU transition, international expansion, and business resilience support programmes operational across Lincolnshire, Leicestershire, Derbyshire, Nottinghamshire, Gloucestershire, Wiltshire, Oxfordshire, Norfolk, Suffolk and the South East Midlands.