EPR for packaging: what you must do as a ‘small producer’

AsIf ayour small organisation (alsoorganisation referredworks towith aspackaging, ‘small producer’ under EPR for packaging regulations) who supplies packaging, you may need to: 

• to register with the regulator 

• regulator, pay a fee 

• collecta and reportfee and report data about the packagingpackaging.

Supplying means carrying‘Works outwith packaging’ means doing one of these activities: things:

• supplying packaged goods to the UK market under your own brand    

  brand   

• placing goods into packaging  

  packaging 

• importing products in packaging    

  packaging   

• selling empty packaging 

  packaging

• hiring or loaning reusable packaging 

  packaging

• running an online marketplace

Throughout the GOV.UK guidance, all these activities are covered by ‘supplying packaging’.

Who this guidance is for

This guidance introduces EPR for packaging to small producers.

‘Small producer’ has a specific meaning in EPR for packaging. It is not related to how many people you employ.

What a ‘small producer’ is

A ‘producer’ is generally a business or other organisation that supplies packaging.

A ‘small producer’ is an organisation that either:

• has an annual turnover of more than £1 million and up to £2 million and supplies more than 25 tonnes of packaging in the UK
• has an annual turnover of more than £1 million and supplies more than 25 tonnes and no more than 50 tonnes of packaging in the UK

The term ‘small producer is not related to how many people you employ.

What information you must collect and report

As a small producer, you must collectkeep datarecords about:

• your ‘packaging activities’ - for example selling, filling or importing packaging
• the ‘class’ of any packaging - for example, packaging for a single sales unit like a crisp packet or packaging for grouping several sales units, like a box for holding many packets of crisps
• what your waste packaging is made of - the ‘packaging material’
• the weight of each packaging material that you’re reporting, in kilograms

Each of the first 3 has a fixed set of categories and codes that you’ll use to report. You must understand these before recording and reporting.

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

You do not need to split plastic into ‘rigid’ and paper‘flexible’ bagspackaging material - you suppliedjust need to report it as ‘plastic’.

Only use these codes in Englandyour reporting:

• SP (small organisation packaging - all)
• HDC (household drinks containers)

Read more information aboutFind packaging activities, classes and materials.out about:

• packaging activities
• packaging classes
• packaging material

When you must report this data

You must report datareport aboutthis thedata wasteonce packaginga youyear. suppliedThe inannual thedeadline previousis calendar1 yearApril.

You by thereport 1 April ofabout thewaste following year.packaging For example,that you mustproduced report packagingin the previous calendar year.

Read guidance about There is guidance that gives more detail about reporting dates and deadlines for both large and small producers, and what to do if you miss a reporting deadline.

Collecting and reporting plastic and paper bag data  

The Environment Agency has issued a Regulatory position statement (RPS) about when you should collect and report data on plastic and paper bags supplied in England.  

The statement also includes information about nation of sale and self-managed organisation waste data, but this does not apply to small producers. 

Read the regulatory position statement to understand how this affects your data submission.

Who you’re reporting to

Each of the 4 nations of the United Kingdom has its own regulator. You’ll be reporting to and monitored by the regulator for your nation.

The regulators are:

• Environment Agency (England)
• Natural Resources Wales
• Scottish Environment Protection Agency
• Northern Ireland Environment Agency

How to report this data

You must report the data using the report packaging data (RPD) service.

Only certain people from an organisation can create an account:

• the director or company secretary
• a partner
• a member of a limited liability partnership

Sole traders can create accounts for themselves.

Create an account on the report packaging data service

More people can be invited to manage your data once you create an account. They’ll be ‘delegates’ and will also have legal responsibilities.

Registering your organisation

Once you’ve made an account, you must register your organisation with the environmental regulators.

The registration fee is £1,216

AsYou’ll parthave ofto registration,upload you need to upload information about your organisation. You’llorganisation, needThis toincludes include informationthings about: like:

• address 

  address

• turnover 

  turnover

• packaging activities 

  activities

• contact details 

  details

• the people who’ll bepeople who’ll be verifying and submitting yourand data 

  submitting your data

You need to upload this information asYou’ll upload this as a CSV file -CSV a type of- spreadsheet. Read a kind of spreadsheet. There is separate guidance that explains allexplaining theexactly informationwhat you needyou need to includesupply, and how to structureto structure the information.

There are also also templates to help you.

Once you’ve submitted your organisation details, your packaging data and paid your registration fees, you can submit your registration application.

Find out more about registering with the regulators, including more details about fees.

Reporting your packaging data

You’ll use the service to upload and submit another CSV file containing your packaging data.

YouThere must use ais fixedguidance setthat ofexplains categorieshow and codes to reportstructure your data,data as follows:

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

2. You do not need to split plastic into ‘rigid’ and ‘flexible’what packagingcodes material - you justmust need to report it as ‘plastic’. use.

3. OnlyThe use thesection codesin SPthat (smallguidance called ‘Small organisation packaging - all)all’ andrules HDCis (householdthe drinksone containers) in your reporting.

Read more guidance that explainsgives howthe tomost structuredetail yourfor datasmall andproducers what- codesfollow you must use.this.

There is a tool that will generate a packaging data file from the data that you have.

There are also example files that show you what a well-formed CSV looks like, although these illustrate large producer submissions at the moment.

Waste disposal fees and recycling obligations

As a small producer, you do not have to pay waste disposal fees or buy packaging waste recycling notes (commonly called ‘PRNs’).

Using a compliance scheme

Compliance schemes are third parties that help organisations meet the EPR for packaging requirements.   

You’ll have to pay a fee to the compliance scheme for their services.

Compliance schemes can:   

• pay your registration fees on your behalf   
• report your packaging data   

A compliance scheme cannot register your organisation on the service.     

If you choose to work with a compliance scheme, you should make sure they appear on the compliance scheme public register.    

 Getting help

If you have any questions, contact your regulator or the EPR for packaging customer service team.

Environment Agency 

Email: packagingproducers@environment-agency.gov.uk 

Natural Resources Wales 

Email: packaging@naturalresourceswales.gov.uk 

Scottish Environment Protection Agency 

Email: producer.responsibility@sepa.org.uk 

Northern Ireland Environment Agency 

Email: packaging@daera-ni.gov.uk 

Defra EPR for packaging customer service 

Telephone: 0300 060 0002  Monday to Friday, 8am to 4:30pm  

Email: EPRCustomerService@defra.gov.uk