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 by Clayton 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.