One of the (many) mysteries of the new EPR regime is the way that the seller nation data has to be reported. A Defra webinar provided some detail, but producers are still left confused, especially as we have yet to see the actual data reporting form that will be required to be used for any of the producer data registration. Given that we are now only two months from when data has to start being reported, it makes it tricky to fully understand how the nation data requirement will work.
However, one thing that has now become clear is who will have to report the nation data. The explanation on GOV.UK suggests that it will only be businesses classed as producers in relation to brand owner/packfill/import etc that are above the threshold of £1m turnover in latest accounts and that are likely to handle >25 tonnes of packaging this year.
A recent query to Defra and the EA has clarified that this is not the case but that any business with a turnover above £1m that SELLs more than 25 tonnes of packaging must report nation data ever if they have none of the other producer obligations.
So a restaurant chain or a small retailer with no own-brand product purely selling packaged good supplied by someone else, will have to report the tonnage of packaging they have supplied to their customers even though this might be completely local. And for the hospitality industry, where they supply packaging products for consumption on the premises – bottles of wine, sugar sachets etc – the start and end nation will be the same but must still be reported.
This will potentially bring tens of thousands of businesses into the EPR reporting requirement, especially in the £1-2m turnover bracket that will never have even heard of the current PRN system, let alone EPR.
This is surely complete lunacy. When businesses are struggling under increasing economic strain and there is still widespread confusion as to the detail of the new system, the application of the nation data – for the sake of the devolved administrations wanting to find out where the packaging discarded in their countries came from – seems like pointless bureaucracy gone mad.