How do you manage EPR?
by Joshua Martin at 15:56 in Environmental, Content
As Extended Producer Responsibility ("EPR") regulations evolve and expand, it can be hard to keep up with the requirements and obligations. A solid data management process is essential to ensure compliance and avoid penalties. In this blog post, we will discuss some of the best practices and tips for managing your EPR data effectively, through these 6 steps:
Legislation Monitoring
Obligation Assessment
Data Collection
Registration
Data and Rule Mapping
Reporting
Legislation Monitoring
The first step needed is legislation monitoring – as changes occur frequently which will affect how and where you report. It is a company's responsibility to keep up to date with changes, and having a way to monitor these is important.
Types of changes to look out for:
Proposed changes : monthly
Reporting changes : quarterly
Passed legislation : bi-annually
Fee updates : annually
Lorax EPI offer two services that can assist with legislation monitoring:
ENVI™ Regulation Lite – our interactive online portal covering global packaging legislation, single use plastics, deposit return systems, labelling and design which is updated on a monthly basis.
Monthly alerts – globally focussed monthly update which covers enacted laws, proposals and initiatives and non-legislative news.
Obligation Assessment
Once you have the information about what legislative changes there are, you need to be able to assess if you are obligated to report.
When conducting an obligation assessment for your business you need to look at:
Who the producer is – some schemes will only charge if you are selling directly to the customer, however some (like the UK PRN system) have a shared obligation system, so will charge the person that imports the packaging, fills the packaging with a product, and who sells it to the end customer.
What products or packaging you have that are in scope (pack level, product type).
Are there any exemptions in the scheme rulings that are applicable to your business?
Thresholds – these could be weight or turnover based, and change depending on the scheme. For example, in the Netherlands, you need to be placing over 50,000kg of packaging onto the market before you need to report. However, in Germany you need to report as soon as you place any products on the market.
In order to ascertain obligation, you will need to gather information about company structure, movement of products, product types, responsibility of shipments and information regarding packaging weights.
The consulting team at Lorax EPI can conduct Obligation Assessments for any markets globally.
Data Collection
Once you have confirmed that you are obligated to report, the next step is data collection as your company needs to be ready to report, in multiple formats, to multiple jurisdictions and organisations, on a wide range of data.
But what do I mean by data? Within EPR reporting, there is little harmonization between schemes – all tend to look at materials and packaging types with a different lens and fee structures vary – which is why it is so important to have an extensive data pool to ensure you are reporting efficiently.
5 main data streams of data needed for current EPR reporting, with examples:
Product – product number / description / brand / weight / content
BOM (Bills of Materials) – validity dates / quantity
Sales – quantity / date / country or province / destination
Packaging component - component numbers / materials / barriers / colours / pack level
Battery / WEEE (if applicable for your products) – weights / chemistry / product type
No one scheme asks for data in the same way as another – which makes data collection very challenging. For more information about data collection and points needed for accurate reporting please contact us directly.
Registration
Once you have collected all of your data, it is your responsibility to register with the relevant schemes. You will need to know the following information:
With whom : do you know who you need to register with? Some countries will just have a single Producer Responsibility Organisation such as Conai in Italy or Citeo in France – whereas other markets will have multiple PRO's you could report into. Additionally you may need to register with a National Authority alongside these (for example, EOAN in Greece).
Who is involved : internally (who needs to complete the documentation within your business) and externally (who do I need to send the complete documentation to?)
What is needed : you will need to gather information on turnover, local contacts and sales office info, product type sold, weights and then you may be asked to carry out historical reporting.
How long : the process can take weeks to months to complete!
Lorax EPI regularly work with clients to register them with obligated schemes, and assist with all historical reporting.
Data and Rule Mapping
You're now registered and ready to report, however one of the biggest challenges in EPR reporting is that you will not be reporting in the same way in any two countries. Each scheme will have their own lens they use of how they approach and categorize data, and how they want to receive it, so you need to have a robust way of managing your data to suit a scheme's specific rules.
Each scheme will have a set of parameters needed for accurate reporting, these will vary from basic information like material information, part weights, part type and pack level, up to more granular data points focussing on labelling, end of life, and barrier materials.
Through our Scoping Service, Lorax are able to provide a Full EPR Parameter List covering:
Global Packaging, WEEE and Battery EPR Schemes
Plastic Tax Reporting
Voluntary Reporting – EMF / US Plastic Pact / UK Plastic Pact
Reporting
The last step in the process is the submission of data to your registered schemes.
Schemes will dictate how they wish to receive their reports, and the variations will be based on:
Format : each scheme will have its own report format that will need to be completed.
Frequency : you could be reporting on monthly, quarterly, bi-annual or annual basis.
Submission : the way you submit your reports to the schemes will vary from web-based portals or direct email submissions.
Through our world-leading EPR reporting software ENVI™, Lorax cover mandatory and voluntary reports across all types of EPR and taxes, such as packaging, WEEE, battery, textiles and plastic taxation on a global basis.
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