Packaging data: what to collect for extended producer responsibility

A guide to collecting data about your packaging. This is for UK organisations affected by extended producer responsibility (EPR) for packaging.

If your organisation is affected by EPR for packaging, you will 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.

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.

Large organisations in Wales should comply with this reporting schedule if they have the required data. If they do not have the required data, they should start collecting data from the date the regulations come into force in Wales in mid-2023, and submit it between 1 January 2024 and 1 April 2024.

Small organisations in Wales should comply with this reporting schedule if they have the required data. If they do not have the required data, they should start collecting data from the date the regulations come into force in Wales from mid-2023, and submit it between 1 January 2024 and 1 April 2024.

You must collect data about the packaging you’ve supplied through the UK market or imported into the UK.

The data you collect must include the following categories:

You 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.

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 report data once a year.

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

You need to tell us what your role was when you supplied the packaging in the UK. You do this by breaking down your data into the different packaging activities. These are:

If you supply packaged goods to the UK market you may need to report ‘nation data’. You can find out more about this in the ‘check if you need to report nation data’ section.

This includes any packaged goods that you supplied under your own brand. A brand includes any of the following:

This applies to all packaging that contains goods, where one or more of the pieces of packaging display your brand.

For example, you may supply a ready meal inside an unbranded plastic tray with film, with a branded carboard 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:

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 packaging.

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 item that has your brand on it, and any other unbranded packaging.

For example, if you supply food hampers, 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.

If you place goods into packaging, and that packaging is unbranded when it’s supplied, you should report it in this category. This could be for goods you packaged for your own organisation or for another organisation.

This includes some packaging around goods that you have imported and gone on to supply or discard in the UK. If you import goods into the UK, the packaging you must report is:

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

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

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. We will let you know more about this process soon.

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

If you hire 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.

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.

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

Large organisations will need to report whether the packaging:

Small organisations need to report:

If you’re a small organisation you do not need to break down your data into the other packaging types.

You must submit the weight of packaging that is:

You should class the following packaging as household:

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 some of your primary and shipment packaging is supplied directly to a business that is the end user of all the packaging, you do not need to report it in this category.

You should class the following packaging as non-household:

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:

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

The environmental regulator will review if you’ve made a robust assessment of whether your packaging is household or 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.

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:

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:

In addition to the evidence listed you may use customer confirmations as a source of evidence. A customer confirmation should 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 should also 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)

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 do not need to report it as household packaging as well.

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

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

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 put on the market 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.

Find out what you need to do if you supply drinks in single-use containers in Scotland.

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

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

You must split your drinks containers data into 2 categories:

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

Most drinks containers will fall into the ‘household drinks containers’ category. This is because they will be made of primary packaging.

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

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

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

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.

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

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:

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

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:

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’.

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

In England, local authorities also commonly collect for recycling:

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

In Scotland, local authorities also commonly collect for recycling:

lids from glass jars

In Wales, local authorities also commonly collect for recycling:

lids from glass jars

This is waste from packaging which:

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

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

This 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.

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:

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.

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 is for grouping several ‘sales units’ for selling or shipping 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 is for shipping single or multiple sales units directly to consumers. This includes cardboard boxes, bubble wrap and mail bags.

For example, if you place a mobile phone in a cardboard box and then place the box into a mail bag before shipping it, the shipment packaging is ‘mail bag’. The primary packaging is ‘cardboard box’.

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’.

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).

You should categorise your data by the following materials:

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

You must report each material type separately.

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

Composite packaging is made of:

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:

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.

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:

You will need to submit your nation data for the 2023 calendar year by 1 December 2024.

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:

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

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.

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:

The environmental regulator will use all of your 2023 data to calculate the amount of packaging waste recycling notes (PRNs) and packaging waste export recycling notes (PERNs) you must buy to cover your recycling obligations for the 2024 calendar year.

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

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.

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.

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

They should record the following information for the shrink wrap:

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:

Second data entry:

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:

They should record the following data for the labels:

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:

Second data entry:

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.

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

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

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

They should collect the following data for the cardboard boxes:

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:

Second data entry:

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

They should collect the following data for the shrink wrap:

They should collect the following data for the plastic wrap:

If you have any questions, contact the packaging team.

Email: [email protected]

This adds a link to the report packaging data service, which has now gone live.

Added Welsh translation

We’ve changed the title of the guidance. We’ve made minor changes to the style, order and some terminology to make the guidance clearer and to reflect the fact that the regulations are now in force. We’ve clarified that this guidance applies to England, Scotland, Northern Ireland and Wales. We’ve added a new section titled ‘When to collect and report your data for 2023’. We’ve updated the names of the 4 different data categories. We’ve also updated the following sections to make them clearer: ‘Supplied under your brand’ packaging; ‘Imported’ packaging; Household and non-household packaging; Drinks containers; Reusable packaging; Self-managed waste; Primary packaging; How parent companies should report data; Check if you need to report nation data; How your data will be used; Examples of how to report data. We’ve added information about multi-material packaging.

First published.