Episodic memory is usually regarded in a Conceptualist light, in the sense of its being dependent upon the grasp of concepts directly relevant to the act of episodic recollection itself, such as a concept of past times and of the self as an experiencer. Given this view, its development is typically timed as being in the early school‐age years (Perner, 2001;Tulving, 2005). We present a minimalist, Non‐Conceptualist approach in opposition to this view, but one that also exists in clear contrast (...) to the kind of minimalism (‘episodic‐like’) espoused byClayton and Dickinson (1998)with regard to memory in food‐caching birds. While emphasising the nonconceptual elements of episodic memory (in common with the ‘episodic‐like’ approach) we also insist on the essentially phenomenological nature of the memory (as does the Conceptualist approach). We propose the third year of life as a plausible onset period. Our view is rooted in Kantian assumptions about the spatiotemporal content of experience (and thus of re‐experience) and about the synthetic unity of experience—and thus of re‐experience. We answer two objections to this position. (shrink)