Environment Agency
If your organisation is affected by EPR for packaging, you may need to report your packaging data.
Find out if you need to report packaging data.
This guidance applies to England, Northern Ireland, Scotland and Wales.
A separate guidance collection covers existing producer responsibility regulations you may need to meet both sets of regulations depending on your situation.
Changes to the data you must report from 2024
There are some changes to the data you must collect and report from 2024 onwards.
These changes are due to take legal effect in all four nations on 1 April 2024, but affect the data that you must submit for the whole of 2024.
These changes affect several areas:
- drinks containers
- filling packaging
- imported goods
- what counts as household packaging
- supplying empty packaging to large organisations
- what packaging sellers are responsible for
Where the rules are changing, they are explained under separate headers in the relevant sections of this guide.
They do not apply to data you collect and report for 2023.
When to collect and report your data for 2023
If you have all the required data recorded from 1 January 2023, you should report this data.
If you do not have all the required data recorded from 1 January, you must report all of your data from 1 March 2023. If you report data that covers a period starting from 1 March, this will be used to calculate a full years worth of data.
Collecting and reporting data for 2023: Wales
Organisations in Wales can comply with this reporting schedule if they have the required data. If you do not have it, you must record and report all your data from 17 July 2023. If you only report data that covers a period starting from 17 July, this will be used to calculate a full years worth of data.
When to collect and report your data for 2024
If you are a large organisation, the data you collect and report in 2024 will be used to calculate your recycling obligation and any waste management fees you must pay in 2025.
If you have all the data under the new rules for 2024, you should report it in 2 batches:
- report your January to June data from 1 July 2024
- report your July to December data from 1 January 2025
If you do not have all the data required under the new rules, you should still report in 2 batches:
- do not report any data relating to packaging supplied between 1 January and 30 March 2024
- report data collected under the new rules from 1 April to 30 June do this from 1 July 2024 and before 1 October 2024
- report your 1 July to 31 December data from 1 January 2025
The environmental regulators will use the data from the 2 submissions to calculate the 3 missing months (January, February and March 2024).
All the data you submit must follow the new rules for data from 2024.
What data you need to collect
You must collect data about the packaging youve supplied within the UK market or imported into the UK.
The data you collect must include the following categories:
- packaging activity for example, supplying under your brand, packing or filling, or importing
- packaging type for example, if the packaging is household or non-household
- packaging class - whether the packaging is primary, secondary, shipment or tertiary
- packaging material and weight
Some organisations may also need to collect nation data. This is information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in. You can find out more about this in the Check if you need to report nation data section of this guide.
Reporting your data
Report your data by submitting a file using the report packaging data service.
Find out how to create your EPR for packaging data file.
Large organisations need to report data every 6 months.
In 2023 and 2024, small organisations will only need to collect data. Small organisations will begin reporting data in 2025 and theyll report once a year.
Find out if youre a small or large organisation, and what this means.
Packaging activity data
You need to tell us what your role was when you imported or supplied the packaging in the UK. You do this by breaking down your data into the different packaging activities. These are:
- supplied under your brand
- packed or filled
- imported (or as first UK owner)
- supplied as empty
- hired or loaned
- supplied through an online marketplace that you own
Some organisations that supply packaged goods to the UK market may need to collect nation data. You can find out more about this in the Check if you need to report nation data section of this guide.
What established in the UK means
An organisation is established in the UK if the registered office, head office or principal place of business is in the UK.
An organisation can also established in the UK if it just has a branch or postal address in the UK. This can be:
- a PO box
- an office
- a warehouse
- domestic premises that are used for business
This is true even if the registered office, head office or principal place of business is outside the UK.
Supplied under your brand packaging
This includes any packaged goods supplied under a brand that you own. A brand includes any of the following:
- a name
- a trademark
- any distinguishing mark
This applies to all filled packaging, where one or more of the pieces of packaging displays the brand you own.
For example, you may supply a ready meal inside an unbranded plastic tray with film, with a branded cardboard sleeve. In this instance, the plastic tray and film should be included as part of the data you report in the supplied under your brand category.
Primary, secondary, shipment and tertiary packaging can all be classed as supplied under your brand packaging.
If you pay another organisation to carry out part of the supply chain for you, you should still report any packaging thats supplied under your own brand. This is the case even if you paid or licensed another organisation to:
- produce goods that youve gone on to supply under your brand
- pack goods that youve gone on to supply under your brand
- supply your branded goods to the UK market
- import your branded goods for you
For packaging with more than one brand
Sometimes packaging around a sales unit displays more than one brand. If this is the case, the organisation that must collect data is the owner of the brand that supplies the sales unit for the first time.
If a sales unit contains packaged items with another organisations brand, you should only collect data for the packaging youve added to the sales unit that has your brand on it, and any other unbranded packaging. However, if there are imported products inside, you may have to report them as imported - see the guidance on imported products below.
Example
If you supply food hampers bearing your brand, you only need to collect data for the hamper and other packaging you add (such as straw, tags, ribbons or bows). You do not need to collect data about any items contained within (such as wine, biscuits or cakes) if they display another organisations brand, unless youve imported that packaging.
There are detailed illustrations and examples in the agreed positions and technical interpretations guidance, produced by the environmental regulators.
There are 2 versions of this document, both stored on the National Packaging Waste Database:
- for data submissions for 2023, check version 3
- for data submissions from 2024 onwards check version 4