Are you ready to report on ALL your activation material too?
Most packaged goods producers by now are all too familiar with the impact of packaging EPR (extended producer responsibility) on their business and operations. Countless business, finance and product leaders in the UK will have had direct experience of collecting packaging data to populate the last two years’ EPR compliance reporting.
People who deal with developing and launching new and updated products every day know there’s far more to product packaging than just a box. Although not everyone in the business is quite as switched on, as we noted in our recent article: Product packaging is more than a box.
Despite this, there is something about EPR that many in both groups may have missed.
UK EPR regulations and associated reporting don’t stop at packaging… they cover activation materials too.
That includes point of sale and merchandising material, promotional materials, giveaways… in fact almost every branded item linked to a product.
Why activation falls in scope of packaging EPR reporting
The rationale for this is actually perfectly clear.
The UK government defines packaging as any material used to cover or protect goods, facilitate handling and delivery, or make goods more appealing for sale.
The first elements of this are well understood, and packaging EPR is influencing how people handle and share information around them.
However, the last element is less well understood in relation to EPR. The definition spans every branded element linked to putting a packaged product on sale – from the point of launch and promotion, into retail distribution, and up to the point of purchase.
So, it applies as much to the freebies and branded merchandise for a new product launch as it does for packaging – and extends into all the ongoing promotion and merchandising.
It makes perfect sense, when you consider it fully.
Volumes of short term, disposable material are produced upfront while launching a new product. Ongoing promotion, marketing and in-store merchandising material continue to be produced throughout its lifecycle.
Why would this not be included?
Savvy product marketers have already recognised the importance of using recycled and recyclable materials in promotional goods. However, many promotional and POS materials often comprise mixed substrates, making them difficult to recycle. These goods enter the waste stream, just as the main packaging does.
The problem with promotional materials
Many producers have already recognised how important it is to centralise and control packaging data – because, if they do not, packaging EPR reporting is likely to be a huge headache (as they may have already experienced).
They face exactly the same problem with activation and promotional material.
The problem may even be slightly worse, if anything.
The information producers need to report on this type of thing is even more distributed than the strands of packaging data.
The data lies scattered across the spreadsheets, email archives and functional point solutions and software of team members in business functions as diverse as product design, marketing, retail space management as well as a host of suppliers and external agencies.
EPR and Activation – what do you need to track?
EPR reporting should also cover the following, in addition to packaging:
- Point-of-Sale Materials such as:
- Free-Standing Display Units
- Counter Display Units
- Shelf Talkers
- Promotional Banners
- Promotional Posters
- Floor Decals
- Branded Merchandise & Giveaways: All the promotional items created to spread brand visibility beyond the store, including but not limited to:
- Pens
- Bags
- Mugs
- Apparel
- Branded giveaways
- Event Activation Materials: All custom and single-use materials for launch or promotional events, including:
- Sampling stations
- Interactive display branding
- Branded tents & booths
- Flyers, posters and handouts
Producers need to identify, track and report on the volumes and materials and recyclability of all the elements of these materials which enter the waste stream.
Help! What to do if you’ve messed up EPR reporting
Clearly, there’s a lot more to packaging EPR than packaging alone.
What should you do if you are only now realising that you may have a wider responsibility to report than you knew – and have already submitted reports with significant gaps?
If you realise that your EPR reporting for the past two years was insufficient, you need to take action. Producers need to submit data that is “as accurate and complete as reasonably possible” or face potential penalties. Plus, your business needs to know what the under-reporting may have created in terms of underpayments.
You need to gather the right information or correct it in your systems and resubmit – alerting the regulator to the problem and paying attention to any guidance they provide.
Whatever happens, you won’t be able to avoid dealing with this in the future. To do so may well require a root and branch reform of how you work with EPR-related data overall and how it connects across the organisation.
That may well include investing in systems that are designed with the capability to help you centralise, connect and control packaging and activation data – like 4Pack.
