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Company Policy Statement: Extended Producer Responsibility (EPR)

Company Policy Statement: Extended Producer Responsibility (EPR) Compliance UK Packaging Supplies Ltd Version 2.0 

Issued: 25 March 2026 | Next Review: 31 March 2027 

 

UK Packaging Supplies Ltd is fully committed to meeting its obligations under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 and the Regulators’ Agreed Positions (Version 8, March 2026). 

We recognise that EPR is a significant regulatory framework designed to improve packaging sustainability, increase recycling rates, and ensure producers bear the net costs of managing household packaging waste. Our approach is guided by the principles of accuracy, transparency, evidence-based decision-making, and continuous improvement. 

Our Core Commitments 

  1. Regulatory Alignment We actively monitor all EPR legislation, guidance, and updates from the Environment Agency, DEFRA, PackUK, and our compliance scheme (Paperpak). We ensure our processes remain aligned with the latest requirements, including data reporting, Nation of Sale allocation, Recyclability Assessment Methodology (RAM), modulated fees, and recycling evidence obligations (PRNs/PERNs). 
  2. Accurate Packaging Data Management We maintain comprehensive records of all packaging we manufacture, import, or supply as a distributor. Data is extracted primarily from our Aptean Merlin ERP system and validated through documented methodologies. We classify packaging as household or non-household using official criteria, with particular attention to distributor obligations for empty/unfilled packaging. All classifications are supported by retained evidence (minimum 7-year retention). 
  3. Supplier & Commercial Collaboration We work closely with suppliers to obtain accurate weights, material specifications, and intended-use information. Where commercial arrangements are in place for the allocation of EPR costs (particularly for volumes supplied to non-large customers), these are governed by documented methodologies and supplier acknowledgements. 
  4. Customer Support & Transparency We provide customers with clear, accurate packaging data, classification guidance, and support upon request. We communicate any material changes to our EPR approach or invoicing in a timely manner and assist customers in understanding their own obligations where our products are involved. 
  5. Governance & Continuous Improvement EPR compliance is overseen by the Head of Compliance. Key methodologies (including our EPR Reporting Methodology, Distributor Percentage Calculation Methodology, and Non-Household Classification Statements) are reviewed at least annually. Staff receive regular training, and all decisions are documented with appropriate audit trails. 

We are committed to minimising our environmental impact while ensuring fair and transparent cost allocation across the supply chain. 

For further information or support regarding our EPR compliance practices, please contact:  

Hamilton Wolfe, Head of Compliance 
compliance@ukplc.co.uk
EPR Registration Number: 100410 

Approved by: Teresa Sullivan, Managing Director Date: 25 March 2026