Defra and the Environment Agency have updated the GOV.UK guidance, “Packaging data: what to collect for extended producer responsibility (EPR)”, which sets out what UK organisations must collect, keep, and report to comply with extended producer responsibility (“EPR”) for packaging. The reported data is used to calculate recycling obligations and (where applicable) waste disposal fees.
Overview of the guidance
The guidance is for any organisation that is a “producer” for EPR packaging purposes, including brand owners, importers/“first UK owners”, packer/fillers, distributors supplying empty packaging, service providers hiring/loaning reusable packaging and online marketplace operators in scope.
The guidance states that organisations must retain packaging data and supporting evidence for at least seven years.
Large vs small producers – what must be reported
The required data set depends on whether an organisation is classified as a large or small producer, and on whether the relevant organisation is “established in the UK”. “Established in the UK” is defined broadly and can include having only a branch or postal address in the UK (e.g., office, warehouse, or business use of domestic premises).
Large producers must report (among other items):
- Packaging activity (e.g., supplied under own brand, packed/filled, imported, supplied as empty, hired/loaned, supplied via an online marketplace)
- Packaging type (e.g., household vs non-household; certain “public bin” packaging; drinks containers; reusable; self-managed waste)
- Packaging class (primary, secondary, shipment, tertiary)
- Packaging material and weight (in kg), including additional detail for certain materials (e.g., plastic rigid/flexible in specified categories)
- Nation data in specified circumstances (nation of sale / nation discarded)
Small producers must report:
- Packaging activity
- Packaging class
- Packaging material and weight
- Using only the reporting codes SP (small organisation packaging – all) and HDC (household drinks containers). The guidance also requires small producers to record all drinks containers as “household drinks containers”
Packaging activity categories include detailed rules for:
- “Supplied under your brand”, including treatment of licensed brands and multi-brand packaging
- “Imported” packaging / “first UK owner” situations
- Online marketplaces: operators may need to report packaging supplied from abroad via the marketplace and must submit a description of the data-collection methodology to the relevant regulator by 1 April following the year reported
Reporting deadlines
For large producers, the reporting deadlines are:
- Jan–Jun data: due 1 October (same year)
- Jul–Dec data: due 1 April (following year)
For small producers, the reporting deadlines are:
- Jan–Dec data: due 1 April (following year)
Nation of sale data for large and small producers where applicable is due 1 April of the following year.
Recyclability Assessment Methodology (RAM)
From 1 January 2025, producers supplying household packaging must assess recyclability under RAM (fee modulation).
Large producers must report RAM data (the guidance notes that the first set of data was due 1 October 2025, covering 1 January–30 June 2025).
Small producers do not report RAM data.
Enforcement note referenced in the guidance (from 1 January 2026)
The guidance states that, where regulators believe an organisation has EPR obligations but has not registered or reported, they may issue a notice of liability, look back up to ten years, and request information from connected organisations. Where liability is found, PackUK may invoice waste disposal fees, and interest may apply to missed/late payments.
Summary of updates to the guidance made on 4 February 2026
The GOV.UK update history states that the 4 February 2026 update was intended to align the guidance with the Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025 and to add clarifications in several operationally important areas. Key changes highlighted include:
A.Multi-brand packaging (responsibility allocation)
The guidance now addresses packaging that displays more than one brand, including rules for determining which brand owner must collect and report data (linked to who makes the first supply of the filled packaging and, if none of the brand owners made the first supply, the largest brand by external surface area).
B.Adding components to packaging after the first supply
The guidance clarifies responsibility where a business adds a new component to packaging (e.g., adding a label) after the packaging has already been supplied by the first producer – responsibility attaches to the added component, while the original packaging remains with the first producer.
C.Closed-loop packaging waste
The update adds/expands content on closed-loop packaging waste (including that it relates to food-grade plastic household packaging collected back and recycled into food-grade plastic) and notes that specific reporting/registration charge requirements can apply.
I.Fibre-based composite – updated definition from 1 January 2026
The guidance reflects a revised classification rule:
- Fibre-based composite applies where plastic layers are more than five per cent by mass and the component cannot be separated by hand.
- If plastic content is five per cent or less, it is classified as paper or cardboard.
The guidance also notes the possibility of resubmitting January–June 2025 data to align with the change (with a resubmission fee referenced).
II.Evidence requirements and resubmission (self-managed consumer waste)
The guidance highlights strengthened/updated evidence expectations (including that evidence must show the waste was recycled in the reporting period, not merely sent for recycling) and introduces a specific resubmission requirement for self-managed consumer waste data submitted for Jan–Jun 2025 before 1 January 2026 (to be resubmitted by 1 April 2026, with no fee per the guidance).
III.Enforcement powers and record-keeping
The update adds information on enforcement approach/powers and reiterates data/evidence retention requirements (seven years) and longer look-back powers for regulators (as summarised above).
IV.Removal of outdated transitional content
The update history indicates that the guidance removed outdated content on the transition period for the 2007 regulations.
V.Plastic/paper bag reporting in England
The guidance now signposts plastic and paper bag reporting in England by reference to the relevant Regulatory Position Statement (RPS 330) and notes that the first mandatory report is for 2026 data (due 1 April 2027).
VI.Other factual/terminology corrections
The update history also notes corrections, including:
- The online marketplace methodology submission deadline (1 April following the year reported);
- Wording clarification for small producer drinks container reporting; and
- Terminology update to “waste disposal fee” (replacing “waste management fee”).
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