Reporting data for EPR – what packaging information do you need to collect under the scheme?

If your business handles packaging in the UK and is classed as a ‘small’ or ‘large’ organisation, you must report packaging data under the forthcoming Extended Producer Responsibility (EPR) regulations. 

With so much information floating about – and much of it still to be confirmed – getting to grips with the new obligations may feel overwhelming, like sitting an exam you didn’t study for. 

As a packaging supplier that reports under EPR and runs our own government-accredited EPR compliance scheme, we can tell you that collecting accurate data is the first step you can towards ensuring compliance. This includes gathering information on:

• Packaging base material 
• Packaging type 
• Anticipated end-of-life waste stream

When and what data you report will depend on whether your business falls under the ‘small’ or ‘large’ organisation category. While ‘large’ organisations must submit packaging data every 6 months, ‘small’ organisations will only need to do so every 12 months. The Scheme Administrator will use this data to determine what modulated fees to charge businesses to cover the cost of recycling household packaging waste. These fees are yet to be finalised, but you can find rough estimates for these in our Extended Producer Responsibility in UK Packaging blog, under ‘Fees’ along with a range of more useful information. 

This reporting for EPR guide outlines everything you need to know about the current and anticipated requirements for submitting your EPR data so you can do so with confidence. 

• Primary packaging – the packaging around a single product, like a bottle of shampoo
• Shipment packaging, for example, a cardboard box used to send goods to a customer 

When does primary of shipment packaging count as ‘non-household’?

• You send it to a business or public organisation that is the final user or removes all packaging before passing the goods on.
• The product is only meant for business or public use and the packaging is unlikely to end up in a household or public bin.
• You import packaging into the UK but throw it away yourself before anyone else uses it.

You must keep proof for all of this for 7 years. If you can’t prove it, you have to treat the packaging as household. Even if the waste is collected by a private service (not by the council), you still can’t count it as non-household unless one of the conditions above applies.

What counts as good evidence?

While the exact conditions for evidence are not yet known, uk.gov lists the following examples as a guideline for what you could use:

• Contracts or agreements saying your customer is not allowed to pass on the packaging.
• Sales records showing that packaging is always removed before the goods are passed on.
• Customer policies (with inspection reports) stating that they don’t supply the packaging further.
• Signed declarations from customers confirming they won’t pass on the packaging, backed by your own checks.
• Customer business info showing they use the product themselves (like a company that uses cleaning chemicals on-site), along with a signed declaration.
• Product details showing that the product is clearly meant only for businesses and not for household use.

However, it is important to note this list isn’t exhaustive. You may need a mix of documents to prove your packaging isn’t household, and what’s acceptable will depend on the specific situation.

For packaging that is sold to both households and businesses, you must report it as household packaging. That is unless you supply it directly to a business or public institution that is the final user, and you have clear proof of this.

Packaging that ends up in public bins

EPR requires you to report the type of material and weight for certain types of household packaging that are commonly thrown away in public bins.

This includes:

• Takeaway food and drink packaging – like wraps, boxes, cups, cup-holders, bags and paper
• Confectionary packaging weighing under 230g, such as chewing gum wrappers and chocolate wrappers
• Tobacco and vape packaging for cigarettes, cigars, tobacco, e-cigarettes and refills
• Paper or plastic (cellophane) straw wrappers
• Packaging for crisps and other savoury snacks weighing under 60g
• Single-serve food packaging for ready-to-eat items like sausage rolls, sushi, sandwiches, biscuits and individual cakes
• Drinks cartons holding up to 850ml, ready to drink without dilution
• Drinks cartons holding up to 600ml, ready to drink without dilution

You only need to report this packaging in the public bin category – you do not have to report it again under household packaging.

It’s important to note that this list is updated regularly, and changes may be made at the end of each reporting year.

Drinks containers

Single-use bottles or cans that hold drinks and are made mainly from:

• Polyethylene terephthalate (PET) plastic
• Glass
• Steel
• Aluminium

They must also hold between 150ml and 3 litres, including if they are sold in multipacks.

Takeaway cups do not count as drinks containers.

Reporting parts like lids and labels

For drinks containers with parts made from other materials:

• For glass containers, report these separately as household packaging
• For PET plastic, aluminium or steel containers, include the weight of those parts in the total and report the container based on the main material

Reporting by business size

Large organisations must split drinks container data into:

• Household drinks containers
• Non-household drinks containers

Small organisations can record all drinks container data as household.

Plastic bags

Bags used at ‘point of sale’ will likely need to be reported, but there is still some uncertainty around other types of bags.

Defra is expected to clarify how to report carrier bags of certain thicknesses, small produce bags and paper bags.

Reusable packaging

If you’re a large organisation, you need to report reusable packaging the first time it is supplied. This data needs to be split into two categories:

• Reusable primary packaging, like a refillable bottle or glass jar
• Non-primary reusable packaging, like pallets or containers

Self-managed packaging waste

Large organisations must also report self-managed waste as one of the following:

• Consumer waste which could be packaging returned by consumers through take-back schemes
• Organisation waste collected from your own sites ( also called backhauled waste)

If you collect waste in one part of the UK and send it to another for recycling, you must report:

• Where the waste was collected
• Where it was sent for recycling
• The type of material and weight

For consumer waste, you only need to report what has actually been recycled.

Self-managed consumer waste

If you handle any consumer waste yourself, you can report it to reduce your household packaging waste fee.

You must submit this data if you also do any of the following:

• Sell or give packaging (empty or filled) to UK customers who will use and dispose of it
• Supply empty packaging to UK businesses that are small or not legally required to report under EPR
• Hire or loan out reusable packaging 
• Own an online marketplace that lets non-UK businesses sell packaging or packaged goods to UK customers
• Import packaged goods for your own use and then throw the packaging away

Any packaging that you have imported and later discarded yourself is also included in this.

Exports

Do you export any of your packaging outside the UK?

EPR rules only apply to packaging used in the UK, so if you export any packaging or goods outside of the UK, you don’t have to pay any EPR fees for them or include them in your data reports.

This is different from the old rules, where you had to record and report this information.

EPR reporting frequency

When should you submit your packaging data?

How often you report data depends on your business size and activity. 

Large organisations

If your business is a large producer, you must now report twice a year instead of annually, replacing the old annual system.

You must report both household and non-household packaging on the same form at the same time. EPR charges apply in addition to PRNs.

Small organisations

If your business has a £1-2 million turnover and handles 25-50 tonnes of packaging, you are exempt from EPR fees but must still submit one annual report. This will help contribute to a more precise understanding of packaging waste in the UK, which is crucial for meeting national recycling and sustainability goals.

Submitting your information

To submit your packaging data, you will need to create an account on the government’s Report Packaging Data portal.

Using your EPR account

Within your account, you can:

• Add your organisation’s details
• Report packaging data
• Declare whether you use a compliance scheme
• Register with environmental regulators
• Accept or reject certain PRNs

Who can create an account

You can create an account if your organisation:

• Supplies packaging in the UK
• Imports and discards packaging in the UK
• Is a third-party, like a compliance scheme

Only certain roles can register an organisation. These are limited to the director or company secretary, a partner, sole trader, or an LLP member.

However, you can invite others to your account and assign permissions to do things on your behalf in the account.

Submitting data

Before submitting data, your account must be approved by the environmental regulator. This can take up to 28 days.

Once approved, you become legally responsible for ensuring data accuracy. If you delegate this task to someone else, they must also be approved and will share the same legal responsibility.

Summary