Packaging data: what to collect for extended producer responsibility

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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 4 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 year’s worth of data.

The deadlines for reporting 2023 data were:

1 October 2023 to report for January to June 2023
1 April 2024 to report for July to December 2023

If you are a large organisation and have not reported your data, contact the environmental regulator.

Collecting and reporting data for 2023: Wales

Large 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 year’s worth of data.

Small producers should collect 2023 data but they do not have to report it.

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.

Small producers must collect their 2024 data and report it by 1 April 2025.

Find out if you’re a small or large organisation, and what this means.

If you have all the data under the new rules for 2024, you should report it in 2 batches:

report your data for 1 January to 30 June from 9 August 2024
report your data for 1 July to 31 December from January 2025

If you do not have all the data required under the new rules, you should still report in 2 batches. In England, Scotland and Wales:

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 9 August 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 you’ve submitted to calculate the 3 missing months (January, February and March 2024).

If you’re reporting 2 batches in Northern Ireland, you should follow these rules, but your first batch only needs to record and report data collected under the new rules from 1 May 2024. This is because the legislation came into force later in Northern Ireland.

All the data you submit must follow the new rules for data from 2024. This applies to all nations.

The deadlines for reporting are:

1 October 2024 to report for January to June 2024
1 April 2025 to report for July to December 2024

What data you need to collect

You must collect data about the packaging you’ve 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.

Small organisations must collect data for 2023 and 2024 and report their 2024 data by 1 April 2025.

Find out if you’re 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 that’s supplied under your own brand. This is the case even if you paid or licensed another organisation to:

produce goods that you’ve gone on to supply under your brand
pack goods that you’ve gone on to supply under your brand
supply your branded goods to the UK market
import your branded goods for you

If you have allowed another organisation to use your brand under a licence agreement, then you are responsible for the branded packaging they supply in the UK, unless it is imported, and you were not responsible for the import, in which case the other organisation should report this packaging as ‘Imported’ packaging.

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 organisation’s brand, you should only collect data for the packaging you’ve 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.

For 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 organisation’s brand, unless you’ve 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 5

‘Packed or filled’ packaging for 2023 data

If you pack or fill unbranded packaging that you own, you should report it in this category. This could be for goods you packaged for your own organisation or for another organisation.

‘Packed or filled’ packaging for data from 2024

From 2024, you should report branded packaging that you’ve packed or filled if all the following are true:

there’s only a packaging manufacturer’s brand on the packaging
the brand does not relate to the product inside
you do not own the brand on the packaging

For example, if you pack and fill Jiffy bags with a product, you’d report the Jiffy bags.

From 2024, you should also report branded packaging that you’ve packed or filled if either of the following are true:

the brand on the packaging belongs to an organisation that is not established in the UK
the brand on the packaging belongs to a UK organisation that is not a large organisation

Keep reporting any unbranded packaging you pack or fill.

‘Imported’ packaging

This includes some filled or unfilled packaging that you have imported and gone on to supply or discard in the UK. The packaging you must report is:

any packaging that’s unbranded after it’s imported
any packaging that is branded but the brand owner is not established in the UK
any packaging that is branded, but the brand owner is not responsible for the import
any packaging you supply to an organisation in the UK that is not classed as a large organisation under EPR for packaging
any filled or unfilled packaging you import into the UK and discard without supplying within the UK or exporting

If you do not know whether an organisation counts as a ‘large organisation’, check the list of large producers who have submitted data to the environmental regulators. The list will be regularly updated. You should also check with the organisation.

You will not be responsible for packaging around filled goods that you’ve imported if they are:

branded, and you’ve imported them on behalf of a brand owner that is established in the UK and is a large organisation
unbranded, and you go on to supply them to a large organisation that applies its brand to them before supplying them on

See the section ‘Packaging class data’ on this page for more information about primary, secondary, tertiary and shipment 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 5

Imported packaging from 2024: unfilled packaging

In 2023, ‘imported’ only covered imported filled packaging.

From 2024, some unfilled packaging is covered too. If unfilled packaging is imported and then discarded by the importer, report it as an importer.

If this unfilled packaging is branded, responsibility depends on who imported it:

if the brand owner is responsible for importing it, they must report it as ‘supplied under your own brand’
if the brand owner is not responsible for importing it, the importer must report it as ‘imported’

Imported packaging from 2024: secondary and tertiary packaging

From 2024 if you import filled branded packaging, you do not have to report secondary and tertiary packaging if all the following are true:

it is branded
the brand owner is a large organisation, established in the UK
the brand owner is responsible for the import

Imports packed by UK third parties: changes for 2024 data

For 2024 data, you’ll also have to report if your organisation sells products to end users where the following are true:

the brand owner is an overseas business that is not established in the UK
a UK third party packs or fills a product into the brand’s packaging before it comes to you – they may also manufacture the product
the overseas brand owner owns the packaging before you purchase it

You are ‘first UK owner’ of these packaged products. Report this packaging under the ‘imported’ packaging activity.

For example, a French company purchases bottle packaging from a UK supplier. They have the packaging sent to a UK company. The French company sends over shampoo in bulk to the same UK company, who put it in the packaging and send the packaged shampoo to the French company’s UK customer, a supermarket. This supermarket is ‘first UK owner’ - they are responsible for the packaging.

‘Supplied through an online marketplace that you own’ packaging

Under EPR for packaging, you’re classed as owning an online marketplace if you operate a website or app that allows non-UK businesses to sell their goods into the UK.

If you own an online marketplace, you should report any filled or unfilled packaging supplied by non-UK businesses through the marketplace in this category. You should only report packaging supplied to the UK market from abroad.

You must also send a description of the methodology you’ve used to collect your data to the relevant environmental regulator before submitting your first set of data.

Find out how to create and submit your methodology.

If your organisation owns a website that supplies goods from UK organisations only, this is not classed as an online marketplace.

‘Hired or loaned’ packaging

If you hire out or loan out reusable packaging, you should report that packaging in this category. You only need to report this packaging the first time it’s supplied.

‘Supplied as empty’ packaging

This includes empty packaging that you’ve manufactured or imported and then supplied to an organisation that is not classed as a large organisation.

If you make or import empty packaging and sell that to a large organisation, you do not need to report that packaging under EPR for packaging, but you do need to keep a record of it.

‘Supplied as empty’: changes for 2024

If you make or import empty packaging and sell that to a large organisation, you will have to report the packaging unless you can show both the following are true:

the large organisation fills or packs the packaging
the large organisation then supplies it to another organisation

Additionally, you will not have to report the packaging if you can prove that once it is filled it will be reported by a large organisation that either:

is the brand owner
packed or filled the packaging

If you do not know whether an organisation counts as a ‘large organisation’, check the list of large producers who have submitted data to the environmental regulators. The list will be regularly updated. You should also check with your organisation.

Packaging type data

You also need to tell us what type of packaging you supply.

Large organisations will need to report whether the packaging:

is household
is non-household
commonly ends up in public bins
is a drinks container
is reusable
becomes self-managed waste

Small organisations need to collect:

their total packaging weight, excluding drinks containers
drinks containers

Household and non-household packaging for 2023 data

You must submit the weight of packaging that is:

household
non-household

Household packaging

You should class the following packaging as household:

primary packaging
shipment packaging

If you supply primary or shipment packaging to a business which supplies it on to another business or an end-consumer, with any packaging included, all packaging should be reported as household packaging. For example, you may supply packaging to a business through a third party such as a distributor or wholesaler.

If you have clear evidence that you supply some of your primary and shipment packaging directly to a business that is the end user of all the packaging, you do not need to report it in this category. Keep records so that you can prove this.

Non-household packaging

You should class the following packaging as non-household:

secondary packaging
tertiary packaging

You should also class primary or shipment packaging as non-household packaging if you supply it to a business which is either of the following:

the end user of the goods contained in the packaging
an organisation that supplies the goods to an end user with all of the packaging removed

You need to be able to show evidence of this. If you cannot, you must class this packaging as household.

How to provide evidence that something is non-household packaging

The environmental regulator will review the evidence that you’ve kept to support your assessment that the packaging is non-household.

Use the evidence listed here as a guide to support your assessment.

You’ll need to keep this evidence for at least 7 years.

Evidence for specialist goods that are for business use only

This applies to bespoke or specialist goods where the end-consumer could only be a business. The end-consumer is also your customer.

In this case, your evidence could include:

bespoke product specifications
invoices (with VAT numbers to evidence business accounts)
customer contacts

Evidence for service or maintenance contracts

This applies to products that are part of a direct supply arrangement. For example, an organisation may supply a product as part of a service agreement.

In this case, your evidence could include:

service contracts
stock replenishment reports

Other evidence

In addition to the evidence listed you may use customer confirmations as a source of evidence. A customer confirmation may help demonstrate that your direct business customer is the end user of the primary and shipment packaging, or they do not supply it on to anybody else.

You may be able to use customer confirmations if you aren’t able to provide any of the evidence listed.

This evidence could include:

supply contracts
written customer confirmations (making it clear that the customer you supplied the packaging to is the end user)

Household and non-household packaging for data from 2024 onwards

There is separate guidance on how to assess household and non-household packaging for data from 2024 onwards.

Packaging that commonly ends up in public bins

You must submit data about the material and weight of household packaging that commonly ends up in public bins. To do this, you should collect data about any of the packaging in the list of ‘items that commonly end up in public bins’.

For any packaging in this category, you only need to report it in this category. You should not report it as household packaging as well.

This is the full list of items that commonly end up in public bins:

packaging provided to consumers with take-away food or drink, including wraps, boxes, cups, cup-holders, bags and paper
packaging on confectionery, where the confectionery weighs less than 230g, including chewing gum packaging and chocolate wrappers
packaging on cigarettes, cigars, tobacco, e-cigarettes and vaping refills
crisp packets or packaging on other savoury snacks, where the crisps or snacks weigh less than 60g
packaging on single portions of food which can be consumed immediately without further preparation, including sausage rolls, sushi, sandwiches, biscuits and individual cakes
cartons holding 850ml or less of drink, whose contents can be consumed immediately without dilution
pouches containing less than 600ml of drink, whose contents can be consumed immediately without dilution

The list of items that commonly end up in public bins is reviewed regularly and may change at the end of the reporting year.

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 5

Changes for 2024 reporting

Straws should no longer be included in items that end up in public bins. They are not packaging – you do not have to report them.

You should still report packaging around straws - for example, a paper or cellophane wrapper.

Drinks containers

You must submit the weight of packaging that’s classed as single-use drinks containers as well as the amount (in units) of drinks containers supplied. You only need to do this for drinks containers that are supplied in England, Wales and Northern Ireland.

You only need to report drinks containers in this category. You do not need to report them in household packaging too.

For data from 2024 onwards, you must also collect and report data on drinks containers that are supplied in Scotland.

What’s classed as a drinks container?

This includes bottles or cans for drinks. They should be made wholly or mainly of any of the following materials:

polyethylene terephthalate (PET) plastic
glass
steel
aluminium

Drinks containers should hold 50ml to 3l of liquid. This includes containers that are 50ml to 3l and supplied in multipacks.

Takeaway cups do not count as drinks containers.

Drinks containers: reporting lids, labels and other parts in 2023 and 2024

If the drinks container has other parts made of different material, like a lid or a label (also known as ‘ancillaries’), there are different rules for 2023 data and 2024 data.

For 2023, you should report these other parts separately, as primary household packaging.

For data from 2024 onwards, only report the other parts of glass drinks containers separately, as primary household packaging. For steel, aluminium and PET containers, include the other parts in the total weight. Report the drinks container as whatever material makes up most of the weight.

How large organisations should categorise drinks containers data

You must split your drinks containers data into 2 categories:

household drinks containers
non-household drinks containers

Read the ‘household and non-household packaging’ section to understand how to do this.

Most drinks containers will fall into the ‘household drinks containers’ category, because they’re supplied to non-business consumers.

If you believe you supply non-household drinks containers, you will need to provide evidence that this is the case.

How small organisations should categorise drinks containers data

You should record all of your drinks containers as ‘household drinks containers’.

Reusable packaging

You only need to report packaging that’s designed to be reused the first time it’s supplied. You will need to split it into 2 categories:

reusable packaging that is primary packaging
reusable packaging that is non-primary packaging

Reporting reusable packaging for 2023 data

For reusable packaging, you should report data in line with the rest of your packaging data (which will be either from 1 January or 1 March). If you do not have all of the required data for reusable packaging from either of these dates, you should report from 1 July 2023.

As well as reporting it in this separate category, you should also make sure any reusable packaging is included in the household and non-household packaging that you report. When you do this, you can only report from 1 January and 1 March.

Reporting reusable packaging for data from 2024 onwards

Report your reusable packaging data in line with the rest of your packaging data.

Self-managed packaging waste

There are 2 things you need to report in the category of self-managed waste:

consumer waste – such as waste you collect through a front of store take-back scheme to offset your household packaging
organisation waste – such as ‘backhauled’ waste

For the self-managed waste you report, you need to tell us about any waste that’s collected in one UK nation and sent to another for recycling. For consumer waste you must only report data for waste that has been recycled.

You need to specify which nation the packaging was collected in and which it was sent to. This must be broken down by weight and material type.

For example, if you collect packaging waste in a grocery store in Scotland but move it to a distribution centre in England before it is sent for recycling, you will need to collect this data.

Self-managed consumer waste

If you’re a large organisation, self-managed consumer waste you report may be used to offset packaging you’ve reported as household packaging. This will reduce your waste management fee.

You will need to report the total weight, broken down by material type. You must have evidence that it has been recycled.

There are 2 different types of self-managed consumer waste:

recovered packaging waste that is not commonly collected by local authorities
reusable packaging waste

Add these together when you report your self-managed consumer waste.

Recovered packaging waste that is not commonly collected by local authorities

You will need to report data about any packaging waste recovered from consumers that you collect through a self-managed recycling scheme.

Examples of these schemes include:

plastic bag collection points in supermarkets
schemes that allow people to return empty crisp packets for recycling

This only applies to packaging waste that is not commonly collected by local authorities.

If you recover waste from consumers that is commonly collected by local authorities, you should report this as ‘self-managed organisation waste’.

Items that are commonly collected by local authorities for recycling

The items that are commonly collected in all UK countries for recycling are:

aerosols
bottles and jars
brown envelopes
cardboard sleeves
cereal boxes
corrugated cardboard
detergent and household cleaner bottles
drinks bottles
drinks cans
egg boxes
foil trays
food pots and tubs
food tins
fruit and vegetable punnets
margarine tubs
milk bottles
toilet roll tubes
toiletries and shampoo bottles
plastic trays
window envelopes
yoghurt pots

In England, local authorities also commonly collect for recycling:

foil
shredded paper

In Northern Ireland, local authorities also commonly collect for recycling:

Tetra Pak and liquid food and drink cartons

In Scotland, local authorities also commonly collect for recycling:

foil
lids from glass jars
shredded paper
Tetra Pak and liquid food and drink cartons

In Wales, local authorities also commonly collect for recycling:

foil
lids from glass jars
shredded paper

Reusable packaging waste

This is waste from packaging which:

has been designed to be re-used and refilled at least once
is now no longer being used as packaging - it has become waste
has been recovered from customers

For example, this could include glass milk bottles that are no longer usable that you have sent for recycling.

How offsetting works

The self-managed consumer waste that you report may be used to offset packaging you’ve reported as household packaging. This will reduce your waste management fee.

You can only offset your household packaging if the material you have collected as part of your self-managed consumer waste is the same packaging material as the household packaging you’ve reported.

For example, if you have collected plastic carrier bags for recycling, as part of a front of store take-back scheme, you can offset this against any plastic packaging you’ve reported in the household packaging category. However, if you have not reported any plastic packaging, there will be no offset applied.

Self-managed organisation waste

You will also need to collect data about all of the packaging waste that you have collected yourself on-site.

This could include ‘backhauling’ or where you’ve arranged for packaging waste to be removed by a private contractor.

This can include:

your own branded packaging waste
other brands’ packaging waste
packaging waste you’ve received from another organisation for ‘backhauling’
unbranded packaging waste
packaging waste you’ve recovered from consumers that is commonly collected by local authorities

For example, you may remove tertiary or secondary packaging from products before displaying them to customers. After removing this packaging, you arrange for it to be collected from your site by a private contractor and sent for recycling. In this instance, you should collect this data and record it in this category.

Packaging class data

Primary packaging

Primary packaging is what’s used to contain a single ‘sales unit’ to sell to customers. For a sales unit that’s made up of lots of items, such as a multipack, the primary packaging includes all of the packaging on the items.

For example, if you sell peas in steel tins with paper labels, the primary packaging is ‘steel tin’ and ‘paper label’.

For a multipack of crisps in plastic bags, the primary packaging is the ‘plastic bags’ around the crisps and the larger ‘plastic bag’ around the crisp packets.

Secondary packaging

Secondary packaging is for grouping several ‘sales units’ for selling or transport purposes. Organisations may also use secondary packaging to display goods in shops.

For example, if you place tins of peas onto a cardboard tray and place the tray onto a supermarket shelf, the secondary packaging is ‘cardboard tray’.

Shipment packaging

Shipment packaging is any packaging added to primary packaging for goods sold online or by mail order and delivered directly to the purchaser or to a shop or collection point. Shipment packaging can include cardboard boxes, bubble wrap and mail bags.

For example, if you sell a mobile phone directly to a purchaser online, in a cardboard box and then place the box into a mail bag before posting it, the primary packaging is the cardboard box and the mail bag is shipment packaging.

Tertiary packaging

Tertiary or transit packaging is used to group secondary packaging units together to protect them while being transported or handled through the supply chain.

Tertiary packaging does not include road, rail, ship and air containers.

For example, if secondary packaging units are placed into larger cardboard boxes that are sealed with plastic parcel tape and put onto wooden pallets to be transported, the tertiary packaging is ‘cardboard box’, ‘plastic tape’ and ‘wooden pallet’.

Packaging material and weight data

After you’ve categorised your data into the relevant packaging activities, you must report the weight of the individual materials.

The packaging material weight should be given in kilograms (kg).

Types of material

You should categorise your data by the following materials:

aluminium
fibre-based composite
glass
paper or cardboard
plastic
steel
wood
‘other’

‘Other’ includes any materials you use that are not listed here. For example, other materials could include:

bamboo
ceramic
copper
cork
hemp
rubber
silicone

You must report each material type separately.

If you report materials under ‘other’, you must give the weight of each material type.

Composite and multi-material packaging

Composite packaging is made of:

2 or more layers of different materials
materials that cannot be separated by hand

For this sort of packaging, you should report the full weight of the packaging and should report it as the main material (the material that weighs the most).

For example, a crisp packet contains plastic and foil. The main material is plastic, so you should report this as plastic.

You should class a material as ‘fibre-based composite’ if both of the following are true:

the main material contains paperboard or paper fibres
the material is laminated with plastic

It may also have layers of other materials.

Multi-material packaging is made from components of different materials. Packaging is multi-material when it is possible to separate it by hand. For example, a yoghurt pot with a cardboard sleeve which can be removed by hand.

For this sort of packaging, you should record the weights of the different materials separately.

Check if you need to report nation data

Nation data is information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in.

If your organisation must act under EPR for packaging, you must submit nation data if you also do any of the following:

supply filled or empty packaging to customers in the UK, where they are the end user of the packaging
supply empty packaging to UK organisations that are either not legally obligated, or are classed as a small organisation
hire or loan out reusable packaging
own an online marketplace through which organisations based outside the UK sell their empty packaging and packaged goods to UK consumers
import packaged goods into the UK for your own use and discard the packaging

Nation data should show where in the UK you’ve supplied packaging to a person or business who’s gone on to discard it.

Supplying packaging includes:

selling
hiring
loaning
gifting
providing in exchange for something other than money
providing because of a statutory duty

This also includes packaging that you’ve imported and then discarded.

How parent companies should report data

If you have registered for EPR for packaging as a parent company, you must submit data for each of the subsidiaries within your group registration separately.

You do not need to include data for any of your subsidiaries that have registered independently.

Find out how EPR for packaging affects parent companies, groups and subsidiaries.

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 5

How your data will be used

Your data is used to work out your waste management fee and your recycling obligations.

The scheme administrator will use some of your data to calculate your waste management fee. To calculate this fee, they will look at your:

household packaging data
packaging that commonly ends up in public bins data

Packaging data that’s been reported under the 2007 regulations

A one-year transitional provision lets organisations discount a portion of their packaging from their recycling obligations if it’s already been reported under the 2007 producer responsibility regulations.

You’ll have to be able to provide evidence that the recycling obligation has been met for any packaging that you want to discount under this provision.

You’ll report this data to the regulators separately - do not make your own deductions when reporting data.

Guidance with more details, including how to report to the regulators, will be published later in the year.

For example, an item of packaging was manufactured, converted and packed in the UK in 2023, then supplied to the end user in 2024. Under the 2007 regulations, the manufacturer, convertor and packer would pick up 52% of the total recycling obligation - the seller would pick up the remaining 48%.

The manufacturer, convertor and packer would collect the data in 2023 and report it in 2024, under the 2007 regulations.The seller’s obligation (48%) would not come under the 2007 regulations because it was supplied in 2024.

In 2024 an organisation becomes obligated under EPR for packaging for 100% of the same item of packaging when it is supplied in the UK.

This means a total recycling obligation of 152% has been created. Under the one-year provision, the organisation obligated under EPR for packaging will be able to discount the excess 52%.

Examples of how to report data

These examples show how you should report your packaging data. They do not show how to report nation data.

Example 1: Imported supermarket groceries

A UK wholesaler imports broccoli from France. It sells the broccoli to a supermarket in the UK. The supermarket then sells the broccoli to consumers under its brand name. The supermarket was responsible for the import of the broccoli and makes this clear on the label.

When the broccoli arrives in the UK, it’s already wrapped in plastic film with a paper label, which has the supermarket’s brand on it. It is stored in a wooden crate.

The wholesaler takes the broccoli out and sends the crate back to France, where it is used again. The wholesaler packs the broccoli into unbranded reusable plastic trays (such as IFCO trays). They put the plastic trays onto hired wooden pallets and secure them with unbranded shrink wrap. They send the pallets to a supermarket.

The supermarket removes the shrink wrap and the pallets. They put the plastic trays onto the shelves for customers to access them. The supermarket sends the reusable plastic trays back to the wholesaler when they are empty. The supermarket recycles the shrink wrap and sends the pallets back to the hiring company.

After a consumer has bought broccoli, they remove the plastic film and label and put it into their bin.

Who needs to collect data?

the wholesaler
the supermarket
the hiring company

Packaging material they should record

shrink wrap
reusable plastic trays
plastic film protecting the broccoli
labels
pallets

The wooden crates that the broccoli was shipped in do not need to be reported. This is because they were sent to another country to be reused.

Data the wholesaler should collect

The wholesaler needs to report the shrink wrap and the reusable plastic boxes.

They should record the following information for the shrink wrap:

packaging activity: packed or filled as unbranded
packaging type: non-household
packaging class: tertiary packaging
packaging material and weight: plastic

They only need to report the reusable plastic boxes the first time they are used. They should record the following 2 data entries for the plastic boxes.

First data entry:

packaging activity: packed or filled as unbranded
packaging type: non-household
packaging class: secondary packaging
packaging material and weight: plastic

Second data entry:

packaging activity: packed or filled as unbranded
packaging type: reusable
packaging class: non-primary packaging
packaging material and weight: plastic

Data the supermarket should collect

The supermarket needs to report the plastic film protecting the broccoli and the labels that have the supermarket’s brand on them.

They should record the following data for the plastic film:

packaging activity: supplied under your brand
packaging type: household
packaging class: primary packaging
packaging material and weight: plastic

They should record the following data for the labels:

packaging activity: supplied under your brand
packaging type: household
packaging class: primary packaging
packaging material and weight: paper

Data the hiring company should collect

The hiring company needs to report the wooden pallets. They only need to do this the first time they hire them out. They should record the following 2 data entries for the wooden pallets.

First data entry:

packaging activity: hired or loaned
packaging type: non-household
packaging class: tertiary packaging
packaging material and weight: wood

Second data entry:

packaging activity: hired or loaned
packaging type: reusable
packaging class: non-primary packaging
packaging material and weight: wood

Example 2: Heat pumps made abroad

An engineering organisation makes heat pumps for people’s homes. They sell them to trade outlets and heat pump installers. The pumps are made in Ireland by the engineering organisation and are shipped to the UK.

After they are made in Ireland, the pumps are put into cardboard boxes that show the engineering organisation’s brand. The boxes are put into a container and shipped to the UK distribution centre of the engineering organisation.

For the pumps that are sent to installers, the engineering organisation places each pump on a wooden pallet. They also place other parts onto the pallet, such as pipes, lubricants and other components. These parts are in unbranded plastic wrap. They secure the pallet with shrink wrap and send it to the installer.

The installer removes all the packaging and recycles it. The installer does not send any of the packaging back to the engineering organisation.

For the pumps that are sent to trade outlets, the pumps are placed onto pallets owned by the engineering organisation, with 6 on each one. The pallets are secured with shrink wrap and sent to trade outlets.

The trade outlet removes the shrink wrap and recycles it. They send the pallets back to the engineering organisation. They put the heat pumps onto their shelves.

They sell the heat pumps in their cardboard boxes. Some go directly to consumers, and some to heat pump installers.

The installers and consumers remove the cardboard boxes and recycle them.

Who needs to collect data?

The engineering organisation is the only one who needs to report data, in this instance.

Who does not need to collect data?

The trade outlets and the heat pump installers do not need to report.

Data the engineering organisation should collect

The engineering organisation needs to collect data about the following packaging materials:

cardboard boxes
pallets
shrink wrap
plastic wrap

They should collect the following data for the cardboard boxes:

packaging activity: supplied under your brand
packaging type: household
packaging class: primary packaging
packaging material and weight: paper or cardboard

They only need to report the returned pallets the first time they are used. They should collect the following 2 data entries about the pallets sent to trade outlets.

First data entry:

packaging activity: packed or filled as unbranded
packaging type: non-household
packaging class: tertiary packaging
packaging material and weight: wood

Second data entry:

packaging activity: packed or filled as unbranded
packaging type: reusable
packaging class: non-primary packaging
packaging material and weight: wood

For the pallets sent to installers (that are recycled), they should collect the following data:

packaging activity: packed or filled as unbranded
packaging type: non-household
packaging class: tertiary packaging
packaging material and weight: wood

They should collect the following data for the shrink wrap:

packaging activity: packed or filled as unbranded
packaging type: non-household
packaging class: tertiary packaging
packaging material and weight: plastic

They should collect the following data for the plastic wrap:

packaging activity: packed or filled as unbranded
packaging type: household
packaging class: primary packaging
packaging material and weight: plastic

Get help and give feedback

If you have any questions, contact the packaging team.

Email: packaging@defra.gov.uk

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Example 1: Imported supermarket groceries

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