Guidance

HowPackaging data: what to collect your packaging data for extended producer responsibility

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

From:
Department for Environment, Food & Rural Affairs and Environment Agency
Published
24 November 2022
Last updated
17 March 2023 — See all updates

If your organisation is affected by EPR for packaging, you will need to report your packaging data.

Find Youout mustif beyou readyneed to report packaging data.

This guidance applies to England, Northern Ireland, Scotland and Wales.

When to collect theand correctreport packagingyour data for 2023

If you have all the required data recorded from the 1 January 2023.2023, Youyou should startreport preparingthis nowdata.

If you do not have all the required data recorded from 1 January, you must report all of your data from the 1 March 2023. If you report data that covers a period starting from 1 March, this will be used to capturecalculate 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.

FindSmall outorganisations in Wales should comply with this reporting schedule if youthey needhave tothe reportrequired packagingdata. 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.

What data you need to collect

You’llYou needmust to collect data about the packaging you’ve handled and supplied through the UK market.

Theremarket shouldor beimported 4into parts to the UK.

The data you collect aboutmust yourinclude packaging.the Thesefollowing are:categories:

  • packaging activity – this is how you putsupplied the packaging
  • packaging ontype – for example, if the market
  • packaging materialis andhousehold weightor non-household
  • packaging typeclass –- whether the packaging is primary, secondary, shipment or transittertiary
  • wastepackaging typematerial and weight

You may also need to collect nation data. This is information about wherewhich nation in the UK your packaging hasis beensupplied sold,in hired,and loaned,which giftednation orin discarded.the UK packaging is discarded in.

Reporting your data

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 must report your data by submitting a file using the ‘Report packaging data’ service.

Find out how to create your EPR for packaging data file.

Packaging activity data

You need to tell us what your role was when you putsupplied the packaging onin the UKUK. market. You do this by breaking down your data into the different packaging activities. These are:

  • supplied under your brand
  • packed or filled as unbranded
  • imported
  • supplied as empty
  • hired or loaned
  • supplied through an online marketplace that you own

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.

‘Supplied under your brand’ packaging

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

  • a logoname
  • a trademark
  • any distinctivedistinguishing mark

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 transittertiary 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 sellsupply under your brand name
  • pack goods that you’ve gone on to sellsupply under your brand name
  • placesupply your branded goods onto 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 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.

‘Packed or filled as unbranded’ packaging

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.

‘Imported’ packaging

This includes some packagedpackaging around goods that you have imported and gone on to sellsupply or discard in the UK. If you import goods into the UK, the packaging you’llyou needmust to report is:

  • transit packaging
  • secondary and tertiary packaging that does not fall under the ‘supplied under your brand’ packaging activity
  • any packaging that’s unbranded when it’s supplied
  • any packaging you sell to an organisation that is not classed as a large organisation under EPR for packaging

If

  • any packaging you import packagedinto goodsthe UK and thendiscard sellwithout theseselling onor toexporting

    • You anwill organisationnot thatbe sellsresponsible themfor topackaging consumersaround underfilled itsgoods ownthat brand:you’ve imported if they are:

    • youbranded, areand responsibleyou’ve forimported thethem packagingon ifbehalf youof importeda thebrand goodsowner withoutthat theis involvementestablished ofin the brand ownerUK
    • theunbranded, brandand owneryou isgo responsibleon forto thesupply packagingthem ifto thea goodslarge wereorganisation importedthat onapplies theirits behalfbrand to them before supplying them on

    See the section ‘Packaging typeclass data’ on this page for more information about primary, secondary, transittertiary and othershipment packaging categories.packaging.

    ‘Supplied asthrough empty’an online marketplace that you own’ packaging

    ThisUnder includesEPR emptyfor packagingpackaging, thatyou’re you’veclassed madeas orowning importedan andonline thenmarketplace suppliedif toyou anoperate organisationa website or app that isallows notnon-UK classedbusinesses asto asell largetheir organisation.goods into the UK.

    ForIf organisationsyou thatown arean notonline classedmarketplace, asyou large,should bothreport ofany thefilled followingor apply:

    • theyunfilled havepackaging ansupplied annualby turnovernon-UK ofbusinesses lessthrough thanthe £2marketplace million
    • theyin handlethis orcategory. supplyYou lessshould thanonly 50report tonnespackaging ofsupplied packagingin athe year
    UK.

    IfYou youmust makealso orsend importa emptydescription packagingof andthe sellmethodology thatyou’ve used to acollect largeyour organisation,data youto dothe notrelevant needenvironmental toregulator reportbefore thatsubmitting packagingyour underfirst EPRset forof packagingdata. butWe will let you doknow needmore toabout keepthis process soon.

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

    ‘Hired or loaned’ packaging

    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.

    ‘Supplied throughas anempty’ online marketplace that you own’ packaging

    AnThis onlineincludes marketplaceempty ispackaging athat websiteyou’ve thatmanufactured hasor beenimported setand upthen supplied to allowan non-UKorganisation organisationsthat tois sellnot theirclassed goodsas online.a large organisation.

    If you ownmake anor onlineimport marketplace,empty packaging and sell that to a large organisation, you shoulddo reportnot anyneed filledto orreport unfilledthat packaging suppliedunder byEPR non-UKfor organisationspackaging, throughbut theyou marketplacedo inneed thisto category.keep a record of it.

    Packaging type data

    IfYou youralso organisationneed ownsto atell websiteus thatwhat sellstype goodsof frompackaging UKyou supply.

    Large organisations only,will thisneed to report whether the packaging:

    • is nothousehold
    • is classednon-household
    • commonly asends anup onlinein marketplace.public bins
    • is a drinks container
    • is reusable
    • becomes self-managed waste

    Small organisations need to report:

    Packaging
    • their materialtotal andpackaging weightweight, data

    excluding drinks containers
  • drinks containers

    • AfterIf you’veyou’re categoriseda small organisation you do not need to break down your data into the relevantother packaging activitiestypes.

    Household youand non-household packaging

    You must reportsubmit the weight of packaging that is:

    • household
    • non-household

    What’s classed as household packaging?

    You should class the individualfollowing materials.packaging as household:

    • primary packaging
    • shipment packaging

    TheIf you supply primary or shipment packaging materialto weighta business which supplies it on to another business or an end-consumer, with any packaging included, all packaging should be givenreported 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 kilogramsthis (kg).category.

    TypesWhat’s ofclassed materialas non-household packaging?

    You should categoriseclass your data by the following materials:packaging as non-household:

    • aluminium
    • fibre-basedsecondary compositepackaging
    • glass
    • papertertiary or cardboardpackaging
    • plastic
    • steel
    • wood
    • ‘other’

    ‘Other’You includesshould anyalso materialsclass youprimary useor thatshipment arepackaging notas listednon-household here.packaging Forif example,you othersupply materialsit couldto include:a business which is either of the following:

    • biodegradablethe plasticsend-consumer (compostableof plasticsthe madegoods ofcontained plant-basedin products)the packaging
    • cork
    • cotton
    • flax-basedan productsorganisation that supplies the goods to an end-consumer with all of the packaging removed
    • nitrile
    • rubber
    • silicone

    You mustneed reportto eachbe materialable typeto separately.

    Ifshow youevidence reportof materialsthis. underIf ‘other’,you cannot, you must giveclass thethis weightpackaging ofas each material type.household.

    How to reportprovide compositeevidence that something is non-household packaging

    CompositeThe environmental regulator will review if you’ve made a robust assessment of whether your packaging is madehousehold of:or non-household. Use the evidence listed here as a guide to support your assessment.

    • 2

      You’ll orneed moreto layerskeep ofthis differentevidence materials

    • materialsfor at least 7 years.

      Evidence for specialist goods that cannotare befor separatedbusiness byuse hand

    only

    ForThis thisapplies sortto ofbespoke packagingor youspecialist shouldgoods reportwhere the weightend-consumer ofcould theonly mainbe materiala –business. thisThe end-consumer is thealso materialyour thatcustomer.

    In weighsthis thecase, most.your evidence could include:

    For

    • bespoke anyproduct compositespecifications
    • invoices packaging(with whereVAT thenumbers mainto materialevidence isbusiness paperboardaccounts)
    • customer contracts

    Evidence for service or papermaintenance fibrescontracts

    This andapplies to products that materialare ispart laminatedof witha plastic,direct yousupply shouldarrangement. classFor thisexample, an organisation may supply a product as ‘fibre-basedpart composite’.of a service agreement.

    Packaging

    In typethis data

    case, your evidence could include:

    • service contracts
    • stock replenishment reports

    PrimaryOther packagingevidence

    PrimaryIn packagingaddition isto the individualevidence containerlisted that you storemay goodsuse incustomer toconfirmations sellas toa consumers.source Thisof includesevidence. multipackA packaging.customer Thisconfirmation should demonstrate that your direct business customer is calledthe aend ‘salesuser unit’.of the primary and shipment packaging, or they do not supply it on to anybody else.

    ForYou example,should also use customer confirmations if you sellaren’t peasable into steelprovide tinsany withof paperthe labels,evidence listed.

    This evidence could include:

    • supply contracts

    • written customer confirmations (making it clear that the primarycustomer packagingyou issupplied ‘steelthe tin’packaging andto ‘paperis label’.the end user)

    Secondary

    Packaging packaging

    that commonly ends up in public bins

    SecondaryYou must submit data about the material and weight of household packaging isthat forcommonly groupingends severalup ‘salesin units’public forbins. sellingTo ordo shippingthis, purposes.you Organisationsshould maycollect alsodata useabout secondaryany of the packaging toin displaythe goodslist of ‘items that commonly end up in shops.public bins’.

    For example,any ifpackaging youin placethis tinscategory, ofyou peasonly ontoneed ato cardboardreport trayit andin placethis thecategory. trayYou ontodo anot supermarketneed shelf,to thereport secondaryit packagingas ishousehold ‘cardboardpackaging tray’.as well.

    Shipment packaging

    ShipmentThis packaging is forthe shippingfull singlelist orof multipleitems salesthat unitscommonly directlyend up in public bins:

    • packaging provided to consumers.consumers Thiswith includestake-away cardboardfood or drink, including wraps, boxes, bubblecups, wrapcup-holders, bags, paper and mailstraws
    • packaging bags.

      Foron example,confectionery, ifwhere youthe placeconfectionery aweighs mobileless phonethan in230g, aincluding cardboardchewing boxgum packaging and thenchocolate placewrappers

    • packaging theon boxcigarettes, intocigars, atobacco mailand bage-cigarettes
    • crisp beforepackets shippingor it,packaging on other savoury snacks, where the shipmentcrisps or snacks weigh less than 60g
    • packaging ison ‘mailsingle bag’.portions Theof primaryfood packagingwhich iscan ‘cardboardbe box’.

    Transitconsumed packaging

    Transitimmediately without further preparation, including sausage rolls, sushi, sandwiches, biscuits and individual cakes

  • cartons holding 850ml or tertiaryless packagingof isdrink, usedwhose tocontents groupcan secondarybe packagingconsumed unitsimmediately togetherwithout todilution
  • pouches protectcontaining themless whilethan being600ml transportedof ordrink, handledwhose throughcontents thecan supplybe chain.

    consumed immediately without dilution

    • TransitThe packaginglist doesof notitems includethat road,commonly rail,end shipup in public bins is reviewed regularly and airmay containers.change at the end of the reporting year.

    Drinks containers

    ForYou example,must ifsubmit secondarythe weight of packaging unitsthat’s areclassed placedas intosingle-use largerdrinks cardboardcontainers boxesas thatwell areas sealedthe withamount plastic(in parcelunits) tapeof anddrinks putcontainers ontosupplied. woodenYou palletsonly need to bedo transported,this thefor transitdrinks packagingcontainers isthat ‘cardboardare box’,put ‘plasticon tape’the market in England, Wales and ‘woodenNorthern pallet’.Ireland.

    Waste type data

    You’llYou alsoonly need to tellreport usdrinks whatcontainers typein ofthis wastecategory. theYou packagingdo isnot likelyneed to becomereport whenthem it’sin discarded.household packaging too.

    LargeFind organisationsout willwhat you need to reportdo whetherif you supply drinks in single-use containers in Scotland.

    What’s classed as a drinks container?

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

    • householdpolyethylene waste
    • non-householdterephthalate waste
    • street(PET) bin wasteplastic
    • a drinks containerglass
    • reusablesteel
    • self-managed wastealuminium

    SmallDrinks organisationscontainers willshould needhold 50ml to report3l whetherof theyliquid. haveThis suppliedincludes packagingcontainers that are 50ml to the3l UKand marketsupplied thatin ismultipacks.

    How alarge drinksorganisations container.should Theycategorise dodrinks notcontainers needdata

    You tomust breaksplit downyour theirdrinks containers data into the2 othercategories:

    • household wastedrinks types.

      containers
    • non-household drinks containers

    Household

    Refer to the ‘household and non-household waste

    packaging’ section to understand how to do this.

    YouMost mustdrinks submitcontainers will fall into the weight‘household drinks containers’ category. This is because they will be made of packagingprimary thatpackaging.

    If endsyou upbelieve (oryou issupply likelynon-household drinks containers, you will need to endprovide up)evidence as:that this is the case.

    • household

      How waste

    • non-householdsmall waste
    organisations should categorise drinks containers data

    What’s

    You classedshould report all of your drinks containers as household‘household waste

    drinks containers’.

    Reusable packaging

    You shouldonly classneed theto followingreport reusable packaging asthe householdfirst waste:time it’s supplied. You will need to split it into 2 categories:

    • reusable packaging that is primary packaging
    • shipmentreusable packaging that is non-primary packaging

    IfFor reusable packaging, you haveshould clearreport evidencedata thatin someline with the rest of your primarypackaging ordata shipment(which packagingwill isbe unlikelyeither tofrom become1 householdJanuary waste,or 1 March). If you do not needhave toall of the required data for reusable packaging from either of these dates, you should report itfrom in1 thisJuly category.2023.

    What’s

    As classedwell 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.

    Self-managed waste

    YouThere shouldare class2 thethings followingyou packagingneed asto non-householdreport in the category of self-managed waste:

    • secondaryconsumer waste – such as waste you collect through a front of store take-back scheme to offset your household packaging
    • transitorganisation packagingwaste – such as ‘backhauled’ waste

    IfFor youthe supplyself-managed primarywaste oryou shipmentreport, packagingyou need to atell businessus whichabout doesany notwaste supplythat’s thatcollected packagingin orone theUK goodsnation itand containssent to anyoneanother else,for thenrecycling. itFor canconsumer bewaste classedyou asmust non-householdonly waste.report You’lldata 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 ablebroken todown showby evidenceweight ofand this.material type.

    IfFor example, if you arecollect unablepackaging waste in a grocery store in Scotland but move it to demonstratea this,distribution centre in England before it is sent for recycling, you shouldwill classneed 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 waste.packaging. This maywill bereduce becauseyour youwaste supplymanagement packagingfee.

    You will need to areport businessthe throughtotal aweight, thirdbroken partydown (suchby asmaterial atype. distributorYou ormust wholesaler).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.

    StreetRecovered binpackaging waste that is not commonly collected by local authorities

    You mustwill submitneed to report data about theany weightpackaging ofwaste packagingrecovered typesfrom consumers that commonlyyou endcollect upthrough ina streetself-managed bins.recycling scheme.

    ForExamples food,of thisthese isschemes packaging for:include:

    • takeawayplastic food,bag suchcollection aspoints wraps,in boxes, bags, papersupermarkets
    • confectioneryschemes that weighsallow lesspeople thanto 230g,return suchempty 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 chewing‘self-managed gumorganisation andwaste’.

    Items chocolatethat are commonly collected by local authorities for recycling

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

    • aerosols
    • crispsbottles and otherjars
    • brown savouryenvelopes
    • cardboard snackssleeves
    • cereal thatboxes
    • corrugated weighcardboard
    • detergent lessand thanhousehold 60gcleaner bottles
    • singledrinks portionsbottles
    • drinks ofcans
    • egg ready-to-eatboxes
    • foil trays
    • food thatpots doesn’tand needtubs
    • food anytins
    • fruit preparation,and suchvegetable aspunnets
    • margarine sausagetubs
    • milk rolls,bottles
    • toilet sushi,roll sandwiches,tubes
    • toiletries individualand cakesshampoo andbottles
    • plastic biscuitstrays
    • window envelopes
    • yoghurt pots

    ForIn drinks,England, thislocal isauthorities packagingalso for:commonly collect for recycling:

    • takeawayfoil
    • shredded drinks,paper

    In suchNorthern asIreland, cups,local cupauthorities holders,also andcommonly strawscollect for recycling:

    • cartonstetra holdingand upliquid tofood 850mland of drink thatcartons

    In doesScotland, notlocal needauthorities toalso becommonly dilutedcollect for recycling:

    • foil
    • pouches

      lids holdingfrom upglass tojars

    • shredded 600mlpaper
    • tetra ofand liquid food and drink thatcartons

    In doesWales, notlocal needauthorities toalso becommonly dilutedcollect for recycling:

    • foil

    • lids from glass jars

    • shredded paper

    For

    Reusable tobaccopackaging products,waste

    This this is waste from packaging for:which:

    • cigaretteshas been re-used and refilled at least once
    • cigarsis now no longer being used as packaging - it has become waste
    • tobaccohas been recovered from customers
    • E-cigarettes

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

    DrinksHow containersoffsetting works

    YouThere mustare submit2 thedifferent weighttypes of self-managed consumer waste:

    • recovered packaging that’swaste classedthat is not commonly collected by local authorities
    • reusable packaging waste

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

    You can only offset your household packaging if the material you have collected as wellpart of your self-managed consumer waste is the same packaging material as the amounthousehold (inpackaging units)you’ve reported.

    For example, if you have collected plastic carrier bags for recycling, as part of drinksa containersfront supplied.of Youstore onlytake-back needscheme, toyou docan offset this foragainst drinksany containersplastic thatpackaging areyou’ve putreported onin the markethousehold inpackaging England,category. WalesHowever, andif Northernyou Ireland.have not reported any plastic packaging, there will be no offset applied.

    Find

    Self-managed outorganisation whatwaste

    You youwill also need to docollect ifdata youabout sellall drinksof inthe single-usepackaging containerswaste inthat Scotland.you have collected yourself on-site.

    This includescould bottlesinclude ‘backhauling’ or canswhere you’ve arranged for drinks.packaging Theywaste shouldto be maderemoved ofby anya ofprivate thecontractor.

    This followingcan materials:include:

    • polyethyleneyour terephthalateown (PET)branded plasticpackaging waste
    • glassother brands’ packaging waste
    • steelpackaging waste you’ve received from another organisation for ‘backhauling’
    • aluminiumunbranded packaging waste
    • packaging waste you’ve recovered from consumers that is commonly collected by local authorities

    DrinksFor containersexample, shouldyou holdmay 50mlremove tertiary or secondary packaging from products before displaying them to 3lcustomers. ofAfter liquid.removing Thisthis includespackaging, containersyou thatarrange arefor 50mlit to 3lbe collected from your site by a private contractor and suppliedsent for recycling. In this instance, you should collect this data and record it in multipacks.this category.

    Packaging class data

    ReusablePrimary packaging

    YouPrimary onlypackaging needis what’s used to submitcontain informationa aboutsingle reusable‘sales packaging,unit’ to sell to customers. For a sales unit that’s made up of lots of items, such as pallets,a multipack, the firstprimary timepackaging theyincludes areall used.of the packaging on the items.

    WhenFor example, if you reportsell yourpeas datain forsteel 2023,tins youwith shouldpaper includelabels, anythe reusableprimary packaging that’sis already‘steel tin’ and ‘paper label’.

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

    Self-managedSecondary wastepackaging

    IfSecondary 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 areplace tins of peas onto a largecardboard organisation,tray youand willplace needthe totray reportonto dataa aboutsupermarket anyshelf, householdthe secondary packaging wasteis ‘cardboard tray’.

    Shipment packaging

    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 collectplace througha mobile phone in a self-managedcardboard recyclingbox scheme.and Thisthen onlyplace appliesthe tobox into a mail bag before shipping it, the shipment packaging wasteis that‘mail bag’. The primary packaging is ‘cardboard box’.

    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 commonlyinclude collectedroad, byrail, localship authorities.and air containers.

    YouFor willexample, needif secondary packaging units are placed into larger cardboard boxes that are sealed with plastic parcel tape and put onto wooden pallets to reportbe transported, the totaltertiary weight,packaging brokenis down‘cardboard bybox’, ‘plastic tape’ and ‘wooden pallet’.

    Packaging material type,and forweight alldata

    After packagingyou’ve youcategorised haveyour collecteddata acrossinto the UK.relevant Youpackaging activities, you must havereport evidencethe thatweight itof hasthe beenindividual recycled.materials.

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

    Types of thesematerial

    You schemesshould include:categorise your data by the following materials:

    • plasticaluminium
    • fibre-based bagcomposite
    • glass
    • paper collectionor points in supermarketscardboard
    • schemesplastic
    • steel
    • wood
    • ‘other’

    ‘Other’ includes any materials you use that alloware peoplenot tolisted returnhere. emptyFor crispexample, packetsother formaterials recyclingcould include:

    • bamboo
    • ceramic
    • copper
    • cork
    • hemp
    • rubber
    • silicone

    You willmust alsoreport needeach tomaterial collecttype dataseparately.

    If aboutyou allreport packagingmaterials wasteunder that‘other’, you movemust acrossgive bordersthe inweight theof UK.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 example,this ifsort of packaging, you collectshould packagingreport inthe afull groceryweight storeof inthe Scotlandpackaging butand moveshould report it toas the main material (the material that weighs the most).

    For example, a distributioncrisp centrepacket incontains Englandplastic beforeand itfoil. isThe sentmain formaterial recycling,is youplastic, willso needyou toshould collectreport this data.as plastic.

    You should reportclass thisa datamaterial byas packaging‘fibre-based typecomposite’ (primary,if secondary,both shipmentof the following are true:

    • the main material is paperboard or transit).paper fibres
    • the material is laminated with plastic

    It may also have layers of other materials.

    YouMulti-material shouldpackaging reportis themade totalfrom amountcomponents of self-manageddifferent wastematerials. youPackaging haveis handled.multi-material Thiswhen includesit youris ownpossible brandedto packaging,separate otherit brands’by packaginghand. andFor unbrandedexample, packaginga thatyoghurt youpot collectwith and/ora movecardboard acrosssleeve borderswhich incan be removed by hand.

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

    Check if you need to report nation data

    Nation data is information about which countrynation in the UK your packaging hasis beensupplied sold,in hired,and loaned,which giftednation orin the UK packaging is discarded in.

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

    • supply filled or empty packaging directly to consumerscustomers in the UKUK, where they are the end user of the packaging
    • supply empty packaging to UK organisations that are either not legally obligatedobligated, underor theare regulationsclassed as a small organisation
    • hire or loan out reusable packaging
    • own an online marketplace where other organisations based outside the UK sell their empty packaging and packaged goods to UK consumers
    • import packagingpackaged togoods into the UK thatfor youyour discardown withoutuse sellingand ordiscard exportingthe itpackaging

    You mustwill 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:

    • selling
    • hiring
    • loaning
    • gifting

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

    How parent companies should report data

    If you have registered for EPR for packaging as a parent company, you’llyou needmust to submit data for each of the subsidiaries within your group separately,registration rather than as a combined group. 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.

    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

    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.

    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 iswas awareresponsible thatfor the broccoliimport hasof beenthe importedbroccoli and makes this clear on the label.

    When the broccoli arrives in the UK, it’s already wrapped in plastic film with a labelpaper andlabel, 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 throwsrecycles away 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 throwput it into their household 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

    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 materialtype: and weight: plasticnon-household
    • packaging type:class: transittertiary packaging
    • wastepackaging type:material non-householdand wasteweight: 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:boxes.

    First data entry:

    • packaging activity: hiredpacked or loanedfilled 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: secondaryreusable
    • packaging class: non-primary packaging
    • wastepackaging type:material non-householdand wasteweight: plastic

    Data the supermarket should collect

    The supermarket needs to report the plastic film protecting the broccoli and the labels.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 materialtype: and weight: plastichousehold
    • packaging type:class: primary packaging
    • wastepackaging type:material householdand wasteweight: plastic

    They should record the following data for the labels:

    • packaging activity: supplied under your brand
    • packaging materialtype: and weight: paperhousehold
    • packaging type:class: primary packaging
    • wastepackaging type:material householdand wasteweight: 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: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: transitreusable
    • packaging class: non-primary packaging
    • wastepackaging type:material non-householdand wasteweight: 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 throwsrecycles itit. away. 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,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 throwsrecycles itit. away. 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 disposerecycle of 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 materialtype: and weight: paper or cardboardhousehold
    • packaging type:class: primary packaging
    • wastepackaging type:material householdand wasteweight: 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:outlets.

    First data entry:

    • packaging activity: hiredpacked or loanedfilled 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: transitreusable
    • packaging class: non-primary packaging
    • wastepackaging type:material non-householdand wasteweight: wood

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

    • packaging activity: packed or filled as unbranded
    • packaging materialtype: and weight: woodnon-household
    • packaging type:class: transittertiary packaging
    • wastepackaging type:material non-householdand wasteweight: wood

    They should collect the following data for the shrink wrap:

    • packaging activity: packed or filled as unbranded
    • packaging materialtype: and weight: plasticnon-household
    • packaging type:class: transittertiary packaging
    • wastepackaging type:material non-householdand wasteweight: plastic

    They should collect the following data for the plastic wrap:

    • packaging activity: packed or filled as unbranded
    • packaging materialtype: and weight: plastichousehold
    • packaging type:class: primary packaging
    • wastepackaging type:material householdand wasteweight: plastic

    Get help

    If you have any questions, contact the packaging team.

    Email: pEPR@defra.gov.uk

    Published 24 November 2022
    Last updated 17 March 2023 + show all updates

    1. 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.

    2. First published.

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