Packaging data: what to collect for extended producer responsibility
Source: gov.uk (2025-08-01)

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

As a large or small organisation affected by EPR for packaging, you must collect and report data about the packaging you supply within or to the UK market.

Find out if you’re affected by EPR for packaging rules (https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do).

The data you report will be used to calculate your recycling obligations and any waste disposal fees (https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-recycling-obligations-and-waste-disposal-fees).

A separate guidance collection covers existing producer responsibility regulations (https://www.gov.uk/government/collections/producer-responsibility-regulations) – you may need to meet both sets of regulations depending on your situation.

Data you must collect and report

The data you must collect and report depends on whether you’re considered a large or small organisation (also referred to as large and small ‘producers’ under EPR). Check if you’re considered a large or small producer (https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do). It also depends on whether the packaging is supplied by an organisation that’s established in the UK.

Large producers

You must report:
- packaging activity data – for example, supplying under your brand, packing or filling, or importing
- packaging type data – for example, if the packaging is household or non-household
- packaging class data – whether the packaging is primary, secondary, shipment or tertiary
- packaging material and weight data
You must also collect information about the recyclability of some packaging. Find out about the recyclability assessment methodology (https://www.gov.uk/guidance/recycling-assessment-methodology-how-to-assess-your-packaging-waste) (RAM).

Read PackUK’s statement on recyclability assessment (https://www.gov.uk/government/publications/packuk-common-2025-recyclability-assessment-requirements/packuk-2025-recyclability-assessment-requirements). This links to regulatory position statements from each of the four regulators. Check the statement from your regulator to understand how this affects your data submission.

You may also need to report 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.

Small producers

You must report:
- packaging activity data
- packaging class data
- packaging material and weight data
Only use these codes in your reporting:
- SP (small organisation packaging - all)
- HDC (household drinks containers)
You must record all of your drinks containers as ‘household drinks containers’.

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

All the differences are explained in more detail in the relevant sections of this guidance.

A separate guide summarises what you must do as a small producer (https://www.gov.uk/guidance/epr-for-packaging-what-you-must-do-as-a-small-producer).

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.

Reporting deadlines

Large and small producers must report their 2024 data by 1 April 2025.

Read more guidance about reporting dates and deadlines for large and small producers (https://www.gov.uk/guidance/packaging-data-check-reporting-periods-and-submission-deadlines), and what to do if you miss a reporting deadline.

Reporting nation of sale data and self-managed organisation waste for 2024 to 2026

The environmental regulators have issued a statement on nation of sale data and data about self-managed organisation waste.

This only applies to nation of sale data and data about self-managed organisation waste. It does not apply to any other data you must collect for EPR for packaging.

Read the regulatory position statement (https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-pepr-producer-data-requirements-rps-330) to understand how this affects your data submission.

Report packaging activity data

As a large or small producer you must report how you supplied packaging within or to the UK market under the following categories – you can report data under more than one category if this applies:
- supplied under your brand
- packed or filled
- imported (or as ‘first UK owner’)
- supplied as empty (for example, if you’re a distributor)
- hired or loaned (service provider)
- supplied through an online marketplace that you own
‘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 another organisation uses your brand under a licence agreement, 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 when it is filled 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. It is currently stored on the National Packaging Waste Database (https://npwd.environment-agency.gov.uk/Public/Guidance.aspx?CategoryId=41fc1dbb-47a2-47fd-bb82-4938d83729e0&ReturnUrl=%2FPublic%2FNewsAndGuidance.aspx%3FReturnUrlId%3D64c793b7-1cf6-ed11-9f3b-98f2b327e115).

‘Packed or filled’ packaging

Report any unbranded packaging you pack or fill.

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.

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
‘Imported’ packaging

You must report filled or unfilled packaging that you have imported and gone on to supply or discard in the UK if:
- it’s unbranded after it’s imported
- it’s branded but the brand owner is not established in the UK
- it’s branded, but the brand owner is not responsible for the import
- you supply to an organisation in the UK that is not classed as a large organisation under EPR for packaging
- you import it into the UK, filled or unfilled, and discard without supplying within the UK or exporting
You do not need to report filled packaging as ‘imported’ if it’s:
- branded, and you’ve imported it on behalf of a brand owner that is established in the UK and is a large organisation
- unbranded, and you go on to supply it to a large organisation that applies its brand to them before supplying them on
The large organisation must report these as ’supplied under your own brand’.

If you do not know whether an organisation counts as a ‘large organisation’, check the list of large producers (https://www.gov.uk/government/publications/list-of-large-producers-on-the-report-packaging-data-service) who have submitted data to the environmental regulators. The list will be regularly updated. You should also check with the organisation.

There are detailed illustrations and examples about importing in the ‘agreed positions and technical interpretations’ guidance, produced by the environmental regulators. It is currently stored on the National Packaging Waste Database (https://npwd.environment-agency.gov.uk/Public/Guidance.aspx?CategoryId=41fc1dbb-47a2-47fd-bb82-4938d83729e0&ReturnUrl=%2FPublic%2FNewsAndGuidance.aspx%3FReturnUrlId%3D64c793b7-1cf6-ed11-9f3b-98f2b327e115).

Importing packaging: secondary and tertiary packaging

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
See the section ‘Packaging class data’ (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility#packaging-class-data) on this page for more information about primary, secondary, tertiary and shipment packaging.

Packaging that’s packed or filled by UK third parties

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 while it’s being filled and 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 (https://www.gov.uk/guidance/packaging-data-tell-us-how-you-collected-it-for-extended-producer-responsibility).

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

Distributors who manufacture or import unfilled (branded or unbranded) packaging must report it as ‘supplied as empty’ unless you sell the packaging to a:
- large UK producer who fills or packs it
- large UK brand owner - who fills it to form part of a branded sales unit
You can check if the organisation you’re selling to is on the list of large producers (https://www.gov.uk/government/publications/list-of-large-producers-on-the-report-packaging-data-service) who have submitted data to the environmental regulators.

Report packaging type data

Large producers need to report whether the packaging:
- is household or non-household
- commonly ends up in public bins
- is a household or non-household drinks container
- is reusable
- becomes self-managed waste
Small producers need to report:
- the total weight of waste packaging, excluding drinks containers
- the weight and number of household drinks containers only
Household and non-household packaging

There is separate guidance on how to assess household and non-household packaging (https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-how-to-assess-household-and-non-household-packaging).

Packaging that commonly ends up in public bins

You must collect and report data about the material and weight of the following household packaging items that commonly ends 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
- packaging around straws - for example, a paper or cellophane wrapper
- 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
You only need to report this data in this category. You should not report it as household packaging as well.

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. It is currently stored on the National Packaging Waste Database (https://npwd.environment-agency.gov.uk/Public/Guidance.aspx?CategoryId=41fc1dbb-47a2-47fd-bb82-4938d83729e0&ReturnUrl=%2FPublic%2FNewsAndGuidance.aspx%3FReturnUrlId%3D64c793b7-1cf6-ed11-9f3b-98f2b327e115).

Drinks containers

Drinks containers include single-use 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 150ml to 3l of liquid. This includes containers that are 150ml to 3l and supplied in multipacks.

Takeaway cups do not count as drinks containers.

Reporting lids, labels and other parts

If the drinks container has other parts made of different material, like a lid or a label (also known as ‘ancillaries’), report these:
- separately, as primary household packaging for glass drinks containers
- as part of the total weight of the container for steel, aluminium and PET drinks containers - report the container as whatever material makes up most of the weight
How large organisations should report drinks containers data

You must split your drinks containers data into 2 categories:
- household drinks containers
- non-household drinks containers
There is separate guidance on how to assess household and non-household packaging (https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-how-to-assess-household-and-non-household-packaging) .

How small producers should report drinks containers data

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

Reusable packaging

Large organisation 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
Self-managed packaging waste

Large organisations report self-managed waste as either:
- 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
The environmental regulators have issued a statement on nation of sale data and data about self-managed organisation waste. Find out more about how this may affect your data submission (https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-pepr-producer-data-requirements-rps-330).

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

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 that’s been reused at least once
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 that you’ve collected from consumers 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 and Wales, local authorities also commonly collect for recycling:
- foil
- lids from glass jars
- shredded paper
- Tetra Pak and liquid food and drink cartons
Reusable packaging waste

This is waste from packaging which:
- has been designed to be re-used and refilled multiple times
- 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.

The environmental regulators have issued a statement on nation of sale data and data about self-managed organisation waste. Find out more about how this may affect your data submission (#rps)

Report packaging class data

Packaging class describes the purpose of the packaging and is split into four categories.

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’.

Report packaging material and weight data

Small and large producers must report the weight in kilograms (kg) of the individual materials for each packaging activity you carry out.

Types of material

You should report data for the following materials:
- aluminium
- fibre-based composite
- glass
- paper or cardboard
- plastic
- steel
- wood
- ‘other’
Report each one separately.

‘Plastic’ subtypes

You must split plastic into ‘rigid’ and ‘flexible’ subtypes if you’re a large producer. Report on each one separately, giving the weight of each.

‘Other’ subtypes

‘Other’ includes any materials you use that are not listed here. For example, other materials could include:
- bamboo
- ceramic
- copper
- cork
- hemp
- rubber
- silicone
These are reported as subtypes of ‘other’.

You must report each material subtype separately. You must give the weight of each material subtype.

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.

Record recyclability data

From 1 January 2025, producers who supply household packaging must assess the recyclability of that packaging. The rating affects the disposal fee that will be charged for that packaging. This is sometimes called ‘fee modulation’.

Large producers must report their first batch of RAM data by 1 October 2025. This will cover 1 January to 30 June 2025.

Small producers do not have to report RAM data.

Find out more by reading:
- an overview of the RAM (https://www.gov.uk/guidance/recycling-assessment-methodology-how-to-assess-your-packaging-waste) that explains the process
- how to assess and rate individual materials (https://www.gov.uk/government/publications/recycling-assessment-methodology-materials-and-outputs) - use this to find red, amber or green ratings for your packaging materials
- definitions and background (https://www.gov.uk/government/publications/recycling-assessment-methodology-background-and-definitions) - this explains the stages of recyclability and some technical terms
Recyclability assessment data: June 2025 regulatory position statement

The environmental regulators have issued a statement on collecting and reporting data under the RAM.

This only applies to Recyclability Assessment Methodology (RAM) data collection and reporting. It does not apply to any other data you must collect and report for EPR for packaging.

Read PackUK’s statement on recyclability assessment (https://www.gov.uk/government/publications/packuk-common-2025-recyclability-assessment-requirements/packuk-2025-recyclability-assessment-requirements). This links to regulatory position statements from each of the four regulators. Check the statement from your regulator to understand how this affects your data submission.

## 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.

The environmental regulators have issued a statement on nation of sale data and data about self-managed organisation waste. Find out more about how this may affect your data submission (#rps)

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 organisationproducer
- 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 to report your data

Report your data by submitting a file using the ‘report packaging data’ service (https://www.gov.uk/guidance/report-packaging-data).

Find out how to create your EPR for packaging data file (https://www.gov.uk/government/publications/packaging-data-how-to-create-your-file-for-extended-producer-responsibility).

Read guidance about when large and small producers need to report data (https://www.gov.uk/guidance/packaging-data-check-reporting-periods-and-submission-deadlines).

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 (https://www.gov.uk/guidance/packaging-waste-prepare-for-extended-producer-responsibility#if-youre-a-parent-company-group-or-subsidiary).

There are detailed illustrations and examples in the ‘agreed positions and technical interpretations’ guidance, produced by the environmental regulators. It is currently stored on the National Packaging Waste Database (https://npwd.environment-agency.gov.uk/Public/Guidance.aspx?CategoryId=41fc1dbb-47a2-47fd-bb82-4938d83729e0&ReturnUrl=%2FPublic%2FNewsAndGuidance.aspx%3FReturnUrlId%3D64c793b7-1cf6-ed11-9f3b-98f2b327e115).

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 (‘transitional reporting’)

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 (https://www.gov.uk/government/collections/producer-responsibility-regulations). This does not discount any waste disposal fees.

This is also known as the ‘dual reporting’ or ‘transitional reporting’ provision.

If you have submitted packaging under the 2007 regulations, met your recycling obligations on this and want the discount to be applied to your obligations for 2025, you must calculate the amount to be discounted and submit this as part of your 2024 packaging data.

This only applies to large organisations.

There are detailed illustrations and examples in the ‘agreed positions and technical interpretations’ guidance, produced by the environmental regulators. It is currently stored on the National Packaging Waste Database (https://npwd.environment-agency.gov.uk/Public/Guidance.aspx?CategoryId=41fc1dbb-47a2-47fd-bb82-4938d83729e0&ReturnUrl=%2FPublic%2FNewsAndGuidance.aspx%3FReturnUrlId%3D64c793b7-1cf6-ed11-9f3b-98f2b327e115).

How to calculate the discount

You must multiply two figures.

First, the amount of packaging, in kilograms, where all the following are true:
- a proportion of the packaging was reported under the 2007 regulations
- someone has met the recycling obligation on the 2007 reporting
- you’ve had to report it again under EPR
This should be done separately for each material.

Secondly, the sum of all the applicable obligations that were applied to it under the 2007 regulations. These are the percentages set out in those regulations - for example, a manufacturer picks up 6% of the recycling obligation, a convertor 9% and a packer/filler 37%.

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.

Example: applying the discount

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 supplies the same packaging under EPR for packaging. The large organisation will have a recycling obligation in 2025 for 100% of the packaging it supplied in 2024.

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%.

If they were reporting 10,000 kg of the material again, they would apply the formula above as follows:

10,000 kg x 52% = 5,200 kg

They would then report both figures:
- 10,000kg of packaging before the discount
- 5,200kg of packaging to be discounted
How to report the amount you want discounted

You’ll submit this as part of your packaging data for the second half of 2024. You’ll have to submit this by 1 April 2025.

The guidance on how to structure your packaging data (https://www.gov.uk/government/publications/packaging-data-how-to-create-your-file-for-extended-producer-responsibility) explains where you will need to add this information to your submission.

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
If you need to see the rules for data from 2023

This guidance covers data collected from 2024 onwards. You can check an archived copy of this guide (https://webarchive.nationalarchives.gov.uk/ukgwa/20250102220903/https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility) to see the rules for data from 2023.

Contact the regulators if you need to report your data from 2023 but have not yet done so.

Get help and give feedback

If you have any questions, contact the packaging team.

Email: xxx@xxx.xx (mailto:xxx@xxx.xx)

Defra is looking for waste and packaging professionals to join a user panel to help improve our services. Find out more information and how to take part in resources and waste research sessions (https://defragroup.eu.qualtrics.com/jfe/form/SV_byGvZLurq3CMkGG).