How to collect your packaging data for extended producer responsibility

If your organisation is affected by EPR for packaging, you will need to report your packaging data. You must be ready to collect the correct packaging data from 1 January 2023. You should start preparing now to capture this data.

Find out if you need to report packaging data.

What data you need to collect

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

There should be 4 parts to the data you collect about your packaging. These are:

• packaging activity – this is how you put the packaging on the market
• packaging material and weight
• packaging type – primary, secondary, shipment or transit
• waste type

You may also need to collect nation data. This is information about where in the UK your packaging has been sold, hired, loaned, gifted or discarded.

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.

Packaging activity data

You need to tell us what your role was when you put the packaging on the UK 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

‘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 logo
• a trademark
• any distinctive mark

Primary, secondary, shipment and transit 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 another organisation to:

• produce goods that you’ve gone on to sell under your brand name
• pack goods that you’ve gone on to sell under your brand name
• place your branded goods on the UK market
• import goods for you

‘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 packaged goods that you have imported and gone on to sell in the UK. If you import goods into the UK, the packaging you’ll need to report is:

• transit packaging
• secondary 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 you import packaged goods and then sell these on to an organisation that sells them to consumers under its own brand:

• you are responsible for the packaging if you imported the goods without the involvement of the brand owner
• the brand owner is responsible for the packaging if the goods were imported on their behalf

See the section ‘Packaging type data’ on this page for more information about primary, secondary, transit and other packaging categories.

‘Supplied as empty’ packaging

This includes empty packaging that you’ve made or imported and then supplied to an organisation that is not classed as a large organisation.

For organisations that are not classed as large, both of the following apply:

• they have an annual turnover of less than £2 million
• they handle or supply less than 50 tonnes of packaging a year

If you make or import empty packaging and sell that to a large organisation, you do not need to report that packaging under EPR for packaging but you do need to keep a record of it.

‘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 through an online marketplace that you own’ packaging

An online marketplace is a website that has been set up to allow non-UK organisations to sell their goods online.

If you own an online marketplace, you should report any filled or unfilled packaging supplied by non-UK organisations through the marketplace in this category.

If your organisation owns a website that sells goods from UK organisations only, this is not classed as an online marketplace.

Packaging material and weight data

After you’ve categorised your data into the relevant packaging activities you must report the weight of the individual materials.

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

Types of material

You should categorise your data by the following materials:

• aluminium
• fibre-based composite
• glass
• paper or cardboard
• plastic
• steel
• wood
• ‘other’

‘Other’ includes any materials you use that are not listed here. For example, other materials could include:

• biodegradable plastics (compostable plastics made of plant-based products)
• cork
• cotton
• flax-based products
• nitrile
• rubber
• silicone

You must report each material type separately.

If you report materials under ‘other’, you must give the weight of each material type.

How to report composite 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 weight of the main material – this is the material that weighs the most.

For any composite packaging where the main material is paperboard or paper fibres and that material is laminated with plastic, you should class this as ‘fibre-based composite’.

Packaging type data

Primary packaging

Primary packaging is the individual container that you store goods in to sell to consumers. This includes multipack packaging. This is called a ‘sales unit’.

Secondary packaging

Secondary packaging is for grouping several ‘sales units’ for selling or shipping purposes. Organisations may also use secondary packaging to display goods in shops.

Shipment packaging

Shipment packaging is for shipping single or multiple sales units directly to consumers. This includes cardboard boxes, bubble wrap and mail bags.

Transit packaging

Transit or tertiary packaging is used to group secondary packaging units together to protect them while being transported or handled through the supply chain.

Transit packaging does not include road, rail, ship and air containers.

Waste type data

You’ll also need to tell us what type of waste the packaging is likely to become when it’s discarded.

Large organisations will need to report whether the packaging is:

• household waste
• non-household waste
• street bin waste
• a drinks container
• reusable
• self-managed waste

Small organisations will need to report whether they have supplied packaging to the UK market that is a drinks container. They do not need to break down their data into the other waste types.

Household and non-household waste

You must submit the weight of packaging that ends up (or is likely to end up) as:

• household waste
• non-household waste

What’s classed as household waste

You should class the following packaging as household waste:

• primary packaging
• shipment packaging

If you have clear evidence that some of your primary or shipment packaging is unlikely to become household waste, you do not need to report it in this category.

What’s classed as non-household waste

You should class the following packaging as non-household waste:

• secondary packaging
• transit packaging

If you supply primary or shipment packaging to a business which does not supply that packaging or the goods it contains to anyone else, then it can be classed as non-household waste. You’ll need to be able to show evidence of this.

If you are unable to demonstrate this, you should class this packaging as household waste. This may be because you supply packaging to a business through a third party (such as a distributor or wholesaler).

Street bin waste

You must submit data about the weight of packaging types that commonly end up in street bins.

For food, this is packaging for:

• takeaway food, such as wraps, boxes, bags, paper
• confectionery that weighs less than 230g, such as chewing gum and chocolate
• crisps and other savoury snacks that weigh less than 60g
• single portions of ready-to-eat food that doesn’t need any preparation, such as sausage rolls, sushi, sandwiches, individual cakes and biscuits

For drinks, this is packaging for:

• takeaway drinks, such as cups, cup holders, and straws
• cartons holding up to 850ml of drink that does not need to be diluted
• pouches holding up to 600ml of drink that does not need to be diluted

For tobacco products, this is packaging for:

• cigarettes
• cigars
• tobacco
• E-cigarettes

Drinks containers

You must submit the weight of packaging that’s classed as single-use drinks containers as well as the amount (in units) of drinks containers supplied. You only need to do this for drinks containers that are put on the market in England, Wales and Northern Ireland.

Find out what you need to do if you sell drinks in single-use containers in Scotland.

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

• polyethylene terephthalate (PET) plastic
• glass
• steel
• aluminium

Drinks containers should hold 50ml to 3l of liquid. This includes containers that are 50ml to 3l and supplied in multipacks.

Reusable packaging

You only need to submit information about reusable packaging, such as pallets, the first time they are used.

When you report your data for 2023, you should include any reusable packaging that’s already in use.

Self-managed waste

If you are a large organisation, you will need to report data about any household packaging waste you collect through a self-managed recycling scheme. This only applies to packaging waste that is not commonly collected by local authorities.

You will need to report the total weight, broken down by material type, for all packaging you have collected across the UK. You must have evidence that it has been recycled.

Examples of these schemes include:

• plastic bag collection points in supermarkets
• schemes that allow people to return empty crisp packets for recycling

You will also need to collect data about all packaging waste that you move across borders in the UK. For example, if you collect packaging 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.

You should report this data by packaging type (primary, secondary, shipment or transit).

You should report the total amount of self-managed waste you have handled. This includes your own branded packaging, other brands’ packaging and unbranded packaging that you collect and/or move across borders in the UK.

Check if you need to report nation data

Nation data is information about which country in the UK your packaging has been sold, hired, loaned, gifted or discarded in.

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

• supply filled or empty packaging directly to consumers in the UK
• supply empty packaging to UK organisations that are not legally obligated under the regulations
• hire or loan out reusable packaging
• own an online marketplace where other organisations sell their empty packaging and packaged goods to UK consumers
• import packaging to the UK that you discard without selling or exporting it

How parent companies should report data

If you have registered for EPR for packaging as a parent company, you’ll need to submit data for each of the subsidiaries within your group separately, rather than as a combined group. You do not need to include any subsidiaries that have registered independently.

Find out how EPR for packaging affects parent companies, groups and subsidiaries.

How your data will be used

The scheme administrator will use your data to calculate your waste management fee.

The regulator will use 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

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 is aware that the broccoli has been imported and makes this clear on the label.

When the broccoli arrives in the UK, it’s already wrapped in plastic film with a label and 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 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 throws 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 throw 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 material and weight: plastic
• packaging type: transit packaging
• waste type: non-household waste

They only need to report the reusable plastic boxes the first time they are used. They should record the following data for the plastic boxes:

• packaging activity: hired or loaned
• packaging material and weight: plastic
• packaging type: secondary packaging
• waste type: non-household waste

Data the supermarket should collect

The supermarket needs to report the plastic film protecting the broccoli and the labels.

They should record the following data for the plastic film:

• packaging activity: supplied under your brand
• packaging material and weight: plastic
• packaging type: primary packaging
• waste type: household waste

They should record the following data for the labels:

• packaging activity: supplied under your brand
• packaging material and weight: paper
• packaging type: primary packaging
• waste type: household waste

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 data for the wooden pallets:

• packaging activity: hired or loaned
• packaging material and weight: wood
• packaging type: transit packaging
• waste type: non-household waste

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 throws it 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, 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 throws it 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 dispose 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 material and weight: paper or cardboard
• packaging type: primary packaging
• waste type: household waste

They only need to report the returned pallets the first time they are used. They should collect the following data about the pallets sent to trade outlets:

• packaging activity: hired or loaned
• packaging material and weight: wood
• packaging type: transit packaging
• waste type: non-household waste

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

• packaging activity: packed or filled as unbranded
• packaging material and weight: wood
• packaging type: transit packaging
• waste type: non-household waste

They should collect the following data for the shrink wrap:

• packaging activity: packed or filled as unbranded
• packaging material and weight: plastic
• packaging type: transit packaging
• waste type: non-household waste

They should collect the following data for the plastic wrap:

• packaging activity: packed or filled as unbranded
• packaging material and weight: plastic
• packaging type: primary packaging
• waste type: household waste

Get help

If you have any questions, contact the packaging team.

Email: pEPR@defra.gov.uk