If your business handles UK packaging, you may now need to report packaging data under the new extended producer responsibility (EPR) regulations. The extended producer responsibility EPR scheme changes how businesses across the UK market manage and report packaging waste, placing greater accountability on organisations that place packaged goods on the market.

For many UK organisations, understanding EPR for packaging starts with knowing what packaging data you must collect and how often you need to report data. Businesses that supply packaging, handle empty packaging, or supply packaged goods must gather accurate information about their packaging material, packaging type, and how that packaging enters the supply chain.

In this guide, we explain how to report packaging data, what information businesses need to report, and how the latest packaging waste regulations affect large organisations, large producers, and companies that operate across the UK market.

Table of Contents

• Packaging Waste Regulations vs Extended Producer Responsibility
• What Packaging Data Do Businesses Need to Collect?
• Packaging Base Material and Composite Packaging
• Packaging Types: Primary, Secondary and Tertiary Packaging
  • Primary Packaging
  • Secondary Packaging
  • Tertiary Packaging
• Ecommerce and Shipment Packaging
• Household Packaging and Non Household Packaging
• Reusable Packaging and Self Managed Waste
• Reporting Drinks Containers and Plastic Bags
• Reporting Nation Data
• Exporting Packaging Outside the UK
• EPR Reporting Frequency for Large Organisations
• Submitting Your Packaging Data
• Using a Compliance Scheme for EPR

Packaging Waste Regulations vs Extended Producer Responsibility

The shift from the previous packaging waste regulations to extended producer responsibility (EPR) represents one of the biggest changes to UK packaging rules in recent years. Under the old system, businesses met their recycling obligations mainly by purchasing packaging recovery notes and waste export recycling notes, while local authorities covered much of the cost of collecting household waste.

The new extended producer responsibility EPR framework changes this approach. Businesses that place packaged goods on the UK market must now take greater responsibility for the environmental impact of their packaging waste.

Key changes introduced by EPR for packaging include:

• Lower obligation thresholds, meaning more UK organisations now need to report their packaging data
• New data reporting requirements through the government reporting portal
• Additional waste management fee charges based on packaging type and recyclability
• Greater scrutiny from environmental regulators on how businesses collect and report their packaging data

The aim of extended producer responsibility is to improve transparency across the supply chain, reduce unnecessary packaging waste, and ensure businesses contribute fairly to the cost of recycling and managing waste.

What Packaging Data Do Businesses Need to Collect?

Under extended producer responsibility, businesses must collect packaging data and report packaging data to demonstrate compliance with the new regulations. Accurate data submissions help environmental regulators understand how much packaging waste is entering the system and how it should be managed.

Most businesses that supply packaging, handle empty packaging, or supply packaged goods on the UK market will need to report information across several categories.

The core packaging data businesses must collect includes:

• Packaging material used in each component
• The packaging type or function of the packaging
• The expected end-of-life waste stream
• The weight of each packaging component
• Where the packaging is supplied and disposed of across the UK (nation data)

This information forms the basis of data reporting under EPR for packaging and ensures regulators receive all the required data to determine waste management fee charges and monitor packaging waste flows.

Businesses that gather clear and consistent packaging data will find it much easier to report packaging, complete data submissions, and remain compliant with extended producer responsibility.

Packaging Base Material and Composite Packaging

When businesses report packaging data, one of the first steps is identifying the packaging material used in each component. Both large organisations and large producers must report data on the weight of each material used in their UK packaging.

Common packaging material types include:

• Aluminium
• Glass
• Plastic
• Steel
• Wood
• Paper or cardboard made from paperboard or paper fibres

In some cases, businesses will also encounter composite packaging or multi material packaging. This refers to packaging made from two or more materials.

For example:

• A carton made from layers of paper fibres, plastic, and aluminium
• A product container with separate removable parts made from different materials

Where packaging contains multiple materials that cannot be separated manually, it should be reported as composite packaging based on the primary material by weight. Some packaging may also fall under fibre composite packaging, where the main material is paperboard laminated with plastic or other materials.

Correctly identifying packaging material types ensures businesses can report packaging data accurately and meet their recycling obligations under extended producer responsibility EPR.

Packaging Types: Primary, Secondary and Tertiary Packaging

Another important part of report packaging data under extended producer responsibility (EPR) is identifying the packaging type used when products move through the supply chain. Businesses must record whether packaging is classed as primary packaging, secondary packaging, or tertiary packaging.

Primary packaging

Primary packaging is the packaging that directly contains a sales unit and protects the product itself. For example, if a bottle of shampoo is sold with a plastic bottle and label, primary packaging includes both of those components.

Secondary packaging

Secondary packaging is used to group secondary packaging units together for storage or retail display. For example, a cardboard tray holding several multipacks of yogurts would be classed as secondary packaging. Although it is not always subject to EPR fees, businesses must still report data on these materials.

Tertiary packaging

Tertiary packaging, sometimes referred to as transit packaging, is used to transport secondary packaging units safely through the supply chain. This could include pallets, wrapping, or other tertiary packaging material used during distribution.

Ecommerce and Shipment Packaging

When goods are sold online and sent directly to UK consumers, any additional packaging used for delivery is classed as ecommerce packaging or shipment packaging. Shipment packaging often includes materials such as cardboard boxes, void fill, and packaging tape.

For example, a product might be packed in its primary packaging and then placed inside a cardboard box with protective filler before shipping. The outer packaging used for delivery becomes shipment packaging, which is considered part of household packaging.

Businesses that supply packaged goods online must report packaging data for this type of packaging because it usually enters the household waste stream. This means companies that UK sell products through ecommerce must record the packaging material, weight, and packaging type used for delivery.

Household Packaging and Non Household Packaging

When completing data reporting for extended producer responsibility EPR, businesses must determine whether their packaging is household packaging or non household packaging.

Household packaging refers to packaging that typically ends up in homes or public bins after products are used. Examples include primary packaging, shipment packaging, and other packaging connected to packaged goods sold to UK consumers.

By contrast, non household packaging is generally used within business environments. This can include secondary packaging, tertiary packaging, or packaging that is removed before products reach the final user.

Correctly identifying household packaging and the non household packaging class is essential when businesses report packaging data, as it determines whether waste management fee charges apply under EPR for packaging.

Reusable Packaging and Self Managed Waste

Under extended producer responsibility (EPR), businesses must also report packaging data for reusable packaging and certain types of waste they manage themselves.

If your organisation uses reusable packaging like plastic pallets, you usually only need to report data the first time that packaging is placed on the UK market. This includes packaging that is designed to be reused multiple times within the supply chain.

Examples of reusable packaging include:

• Refillable bottles or containers used for packaged goods
• Reusable crates or pallets used to supply packaging to retailers
• Containers used in a reusable packaging supply system

Businesses may also need to report self managed waste where packaging waste is collected and handled outside standard waste collection systems.

This can include:

• Consumer waste returned through take-back or collection schemes
• Packaging waste collected directly from company sites
• Self managed consumer waste that the business arranges to recycle itself

Accurately recording this information ensures businesses meet their recycling obligations and correctly report packaging data under EPR for packaging.

Reporting Drinks Containers and Plastic Bags

Some types of household packaging require additional data reporting under extended producer responsibility.

One key category is drinks containers. Businesses must report data on certain single-use containers made from materials such as plastic, aluminium, steel, or glass. These containers typically hold between 150ml and 3 litres and are commonly used for beverages sold to UK consumers.

When reporting drinks container data, businesses should record:

• The material used for the container
• The total weight of the container
• Any additional packaging components such as lids or labels

Another category businesses may need to report packaging data on is plastic bags. These may include bags provided at the point of sale or used to package packaged goods before they are supplied to customers.

Although guidance continues to evolve, businesses should track plastic bags used to supply packaged goods and include them in their packaging data where required.

Reporting Nation Data

As part of extended producer responsibility EPR, businesses must also report nation data. This means specifying where packaging is supplied and disposed of across the UK.

Companies must submit nation data if they carry out activities such as:

• Selling or giving empty packaging or filled packaging to UK consumers
• Supplying empty packaging to other UK organisations that do not report under EPR
• Operating an online marketplace where non UK businesses sell packaged goods to UK customers
• Hiring or loaning reusable packaging through an online marketplace hire model
• Importing goods and later choosing to discard packaging themselves

These requirements help regulators understand where packaging waste is generated and ensure businesses accurately report nation data and submit data under the extended producer responsibility framework.

Exporting Packaging Outside the UK

If your business exports packaged goods or empty packaging outside the UK market, those items are generally not included in EPR for packaging requirements.

Under extended producer responsibility, businesses only need to report packaging data for packaging that is used and disposed of within the UK. Packaging that leaves the country does not contribute to UK packaging waste totals and therefore does not attract a waste management fee.

However, businesses should still keep records of exported packaging to ensure their submitted data accurately reflects what has been placed on the UK market.

EPR Reporting Frequency for Large Organisations

How often you report packaging data depends on the size of your business.

Large organisations and large producers must now complete data reporting twice per year rather than submitting a single annual report.

Large organisations must:

• Report packaging data every six months
• Include both household packaging and non household packaging in their data submissions
• Provide accurate packaging data covering primary packaging, secondary packaging, tertiary packaging, and shipment packaging

Smaller businesses still need to report their packaging data, but typically only submit one annual report. Even where waste management fee charges do not apply, accurate packaging data helps regulators understand how much packaging waste is produced across the UK market.

EPR Reporting Frequency for Large Organisations

How often you report packaging data depends on the size of your business.

Large organisations and large producers must now complete data reporting twice per year rather than submitting a single annual report.

Large organisations must:

• Report packaging data every six months
• Include both household packaging and non household packaging in their data submissions
• Provide accurate packaging data covering primary packaging, secondary packaging, tertiary packaging, and shipment packaging

Smaller businesses still need to report their packaging data, but typically only submit one annual report. Even where waste management fee charges do not apply, accurate packaging data helps regulators understand how much packaging waste is produced across the UK market.

Using a Compliance Scheme for EPR

Managing EPR for packaging, gathering packaging data, and ensuring you report packaging data correctly can be complex, particularly for large organisations handling significant volumes of packaged goods or empty packaging.

Working with a trusted compliance scheme can help simplify the process. A recognised compliance scheme can support businesses with data reporting, regulatory guidance, and ensuring they meet their obligations under extended producer responsibility EPR.

If your organisation needs support navigating EPR for packaging, contact Kite Packaging to learn how our team and compliance scheme can help you stay compliant.