Extended Producer Responsibility for Packaging (pEPR) fibre-based composite and paper and board obligations: RPS 351
Environment Agency regulatory position on producer responsibility obligations relating to fibre-based composite (FBC) and paper and board packaging materials for 2025.
Applies to England
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This regulatory position statement (RPS) allows you to adopt the forthcoming amendment to the meaning of FBC and introduction of a definition of paper and board. You can apply these changes when complying with your producer responsibility obligations for 2025, before these amendments are made to the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.
This RPS does not change your legal requirement to apply the current definition of FBC when complying with your producer responsibility obligations under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (the 2024 regulations).
However, the Environment Agency will not normally take enforcement action if you do not apply the definition of FBC currently in force but choose to apply the forthcoming definitions of FBC and paper and board.
If you are a member of a compliance scheme or group registration, some of your producer responsibility obligations fall to your scheme operator or holding company, as set out in the 2024 regulations.
The regulatory position does not change or remove your legal obligation to apply the current definition of FBC material under the 2024 regulations.