Record and submit your methodology for collecting packaging data
Source: gov.uk (2025-09-18)

How to document the way you collect your packaging and packaging waste data - known as your ‘methodology' - as an online marketplace or other producer obligated under extended producer responsibility (EPR) for packaging. Including who must submit this information and submission deadlines.

If you’re affected by extended producer responsibility (EPR) for packaging, you may need to report data on the packaging you supply. This must be as accurate as reasonably possible.

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

You may also need to submit a document telling the environmental regulators how you gathered and recorded your packaging data. This is known as your ‘methodology’. It helps show that your data accurately represents the packaging you’re responsible for.

All methodologies must be reviewed and updated regularly to reflect changes to suppliers and products.

Methodologies submitted after 1 October 2025 must include information about recyclability assessments under the Recyclability Assessment Methodology (RAM).

Check if you need to submit a methodology

Online marketplaces must submit a methodology. Online marketplaces are businesses that operate a website or app allowing non-UK businesses to sell their goods into the UK.

Online marketplaces must submit their methodology on or before 1 April each year for the previous calendar year. For example, you should report your methodology for 2025 on or before 1 April 2026.

Other producers

Other organisations obligated under EPR for packaging do not have to submit a methodology. However, having one can provide evidence that:
- you have a clear process in place
- your data is as accurate as reasonably possible
- you have a documented process that is resilient if there is a change to staff or similar disruption
This information may be used as part of compliance audits by the environmental regulators.

Information you should include in your methodology

Your methodology should include:
- a summary of the methodology
- details of your method – for example, sample selection and sizes
- details of how you’ve assessed packaging under the RAM (after 1 October 2025)
- information about the technology used
- any supporting data
- information about future improvement
You should keep all relevant information used in developing your methodology in case it needs validation or is audited.

Summary

Your summary should explain what you’ve included and what you’ve left out. For example, you may be excluding exports from your reporting because they are not obligated.

It should also explain who in your business will be sampling, recording and submitting the data.

Your method

Your method should explain how you:
- collect your data
- ensure it is accurate and representative
You should include information about:
- sampling
- packaging data
- your suppliers
- your customers
Sample information

This should:
- include your sample size
- explain why you chose certain samples
- explain how the samples and sample sizes you chose represent your product range
- explain how the samples represent your suppliers - for example, using more samples for larger suppliers
- give details of the sampling procedures - for example, whether product grouping is used and if so, how and where
- explain how the weights are quality assured, for example using calibrated scales
Packaging information

This should show:
- how you worked out the packaging weight
- your quality assurance process for calculating packaging weight
- how you assigned the packaging type
- how you identified household packaging
- the evidence you used to confirm non-household packaging
- how you define unfilled packaging
- how you collect information for seasonal products
Supplier information

This should explain:
- how you validate weights and other information provided by suppliers
- how you check that scales used by suppliers are accurate, and appropriate for the size and weight of packaging
- what you do when you are unable to obtain data from suppliers
- what you will do to increase the amount of data you get from your suppliers in the future, and how you’ll achieve this
Customer details

This should explain:
- how you identify business customers who are not legally obligated under EPR for packaging
- how you work out the weight for packaging supplied by organisations that use your online marketplace to supply packaging
Recyclability assessments

From 1 October 2025 your methodology document must include recyclability assessment information under the RAM. You must give information about how:
- you assessed the recyclability of the packaging according to each stage of the RAM guidance (https://www.gov.uk/guidance/recycling-assessment-methodology-how-to-assess-your-packaging-waste)
- you evidenced the stages and outcome of assessments
- you determine medical packaging that is red by virtue of regulatory requirement (RBVORR) (https://www.gov.uk/guidance/recyclability-assessment-methodology-supplementary-guidance), if this applies
- often you carry out assessments
- you keep records of those assessments
- you report your recyclability assessments
Your document can also include information about how you:
- take any seasonal variations into account
- use the information you’ve collected – for example, how you determined your top products
- find out information from your suppliers and customers, including questions you ask them
- group or categorise your products for sale and how you’ve used this in your data
- verify weight data that suppliers have given you
- collect nation data
- account for any extra packaging that your company uses on top of the original packaging
Information about the technology you use

This should include information about:
- details of the IT system you use to record data (including RAM data)
- how you collect, record, process and report your data (including RAM data)
- who is responsible for gathering, uploading and approving the data
- how long you store your data for
- your version control process, if you have one
- how you back up your data
- how your weights are stored – whether updates overwrite them completely or there’s a history
- how you ensure the integrity of the data
Provide supporting data

There should be supporting information that covers:
- any anomalies you’ve found, such as weights, packaging and seasonal variations
- all background weights gathered as part of the sampling exercise and, if applicable, the average for a given size and type of packaging
- the process for gathering and reporting data including RAM data, ideally as a flow diagram
- any assumptions made when collecting the data or grouping products
- the type of quality assurance done, including information on who did this and when they did it
- an outline of any information you’d share with the environmental regulator before an audit
- records of recyclability assessments (evidence required for RAM)
Continuous improvement

You must review and update your packaging methodology at least once per reporting cycle. You should explain how you’ll do this to reflect changes such as:
- business expansion
- additional brands
- changes to packaging materials
- change in activity and suppliers
- changes and improvements to your estimates and assumptions as you gather more data
- changes to RAM reporting requirements
- changes to packaging subcategories
- changes to the list of packaging that commonly ends up in public bins (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility), if you supply public binned packaging
- changes to the list of commonly collected items (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility), if you’re reporting self-managed consumer waste
The document should support or explain how you will achieve a continual improvement in the quality of your data.

This may include frequency of repeat sampling and quality assurance to ensure that the methodology is still appropriate.

Deadlines for submitting your methodology

Online marketplaces must submit a methodology for the previous calendar year, on or before 1 April of the following year. You must submit your methodology each year unless:
- it has not changed from the one previously submitted - you must email your environmental regulator on or before 1 April to confirm this
- you resubmitted your packaging and packaging waste data after 1 April as a result of refining your methodology for that year – you should resubmit your updated methodology as soon as possible
If you submit a methodology after 1 October 2025, this must include information about recyclability assessments under the RAM.

How to submit your methodology

Email your completed methodology as a Word document to the environmental regulator for your nation. Email:
- the Environment Agency (England): xxx@xxx.xx (mailto:xxx@xxx.xx)
- Natural Resources Wales: xxx@xxx.xx (mailto:xxx@xxx.xx)
- the Northern Ireland Environment Agency: xxx@xxx.xx (mailto:xxx@xxx.xx)
- the Scottish Environment Protection Agency: xxx@xxx.xx (mailto:xxx@xxx.xx)
Include your organisation number in the email. You’ll get this number when you create your account to report packaging data.

If you used another organisation’s methodology, for example from a compliance scheme, you must:
- give details about the methodology
- explain how it was used
- explain why it is representative of your packaging data
After you’ve submitted your methodology

The environmental regulator may contact you with queries about your methodology.

If the regulator for your nation identifies an issue, you may be asked to revise your methodology and submit it again. You may also need to update and re-submit your packaging data. This is to ensure all your data is as accurate as possible.