pEPR brings a fundamental change to how waste is regulated

By Sally O’Kane | GIRAFFE Associates Ltd

Under Packaging Extended Producer Responsibility (pEPR), the “polluter pays” principle fundamentally shifts how packaging waste is regulated and funded across the UK and ROI.

It’s common to assume packaging compliance only applies to retail brands, however the construction sector is directly exposed. High-volume, heavy materials, such as wooden delivery pallets, heavy-gauge scaffold shrink wrap (250-micron UV film), composite protective coverings, and bulk strapping, can rapidly push businesses past legal reporting and fee thresholds.

It’s clear to us that few construction companies are aware of this liability, so here’s some clarification.

The Thresholds: Where Do You Stand?

Operating across the UK and ROI means navigating two distinct regulatory frameworks:

UK & Northern Ireland (UK pEPR Framework)

• Large Organisations (£2m+ turnover AND 50+ tonnes packaging/year): Mandatory bi-annual data reporting, packaging waste management fee payments (modulated by recyclability), and PRN/PERN purchasing.
• Small Organisations (£1m+ turnover AND 25+ tonnes packaging/year): Mandatory annual packaging data collection and submission via the Report Packaging Data service.

Republic of Ireland (ROI pEPR / Repak Scheme):

• Major Producers (€1m+ turnover AND 10+ tonnes packaging placed on the market): Mandatory registration and membership with Repak under EPA oversight, half-yearly data reporting by material type, and statutory recycling fee payments.

Three Key Exposure Points for Construction & Fit-Out Teams

1. Skipping Pallets and Wrap: Throwing untreated delivery pallets or plastic shrink film into general mixed C&D skips incurs a double financial hit: standard skip disposal fees under Duty of Care plus unmitigated pEPR fee liabilities.
2. Importing Specialist Materials & Systems: If your business acts as the importer of record bringing architectural components, specialist fit-out assemblies, MEP modules, or bulk construction products from the UK/Europe onto an Irish project site (or vice versa), you legally become the primary “Producer” responsible for secondary and tertiary transit packaging.
3. Subcontractor Packaging: Without clear procurement clauses, principal contractors risk inheriting unrecorded packaging liabilities brought onto site by Tier-1 trade packages.

Immediate Next Steps

Construction businesses should not wait for fee assessments to land. Establishing a weight-based packaging audit, mapping supply chain imports, and implementing formal supplier pallet take-back loops are essential first steps to legally offset tonnage and reduce overall liability.

Need support auditing your packaging weights or calculating your legal obligations? GIRAFFE Associates can help your commercial and operational teams get pEPR-ready.