DataChanges to the data you must collectreport andfrom report 2024 

TheThere are some changes to the data you must collect and report dependsfrom 2024 onwards. 

These changes are due to take legal effect in all 4 four nations on whether1 you’reApril considered2024, abut largeaffect orthe smalldata organisationthat (alsoyou referredmust tosubmit asfor largethe andwhole smallof ‘producers’2024. 

These underchanges EPR).affect Checkseveral ifareas:

• drinks you’recontainers
• filling consideredpackaging
• imported agoods
• what largecounts oras smallhousehold producer.   Itpackaging
• supplying alsoempty dependspackaging onto whetherlarge theorganisations
• what packaging issellers suppliedare byresponsible anfor

Where organisationthe that’srules establishedare changing, they are explained under separate headers in the UK. relevant sections of this guide.   

Large

They producers 

When to collect and report your data for 2023 

YouIf mustyou report: have all the required data recorded from 1 January 2023, you should report this data. 

• packaging

  If activityyou do not have all the required data –recorded forfrom example,1 supplyingJanuary, underyou must report all of your brand,data packingfrom or1 filling,March or2023. importing 

• packagingIf typeyou report data –that forcovers example,a ifperiod thestarting packagingfrom is1 householdMarch, orthis non-household 
• packagingwill classbe used to calculate a full year’s worth of data. 

  The deadlines for reporting 2023 data –were:

  • 1 whetherOctober the2023 packagingto isreport primary,for secondary,January shipmentto orJune tertiary  2023  
  • packaging1 materialApril and2024 weightto data report for July to December 2023

  YouIf mustyou alsoare collecta informationlarge aboutorganisation and have not reported your data, contact the recyclabilityenvironmental ofregulator.

  Collecting someand packaging.reporting Finddata outfor about2023: Wales 

  Large organisations in Wales can comply with this reporting schedule if they have the recyclabilityrequired assessmentdata. methodologyIf (RAM). you do not have it, you must record and report all your data from 17 July 2023. If you only report data that covers a period starting from 17 July, this will be used to calculate a full year’s worth of data. 

  YouSmall mayproducers alsoshould needcollect 2023 data but they do not have to report nationit.

  When data.to Thiscollect isand informationreport aboutyour whichdata nationfor in2024 

  If you are a large organisation, the UKdata packagingyou iscollect suppliedand report in 2024 will be used to calculate your recycling obligation and whichany nationwaste inmanagement thefees UKyou packagingmust ispay discardedin in. 2025. 

  Small producers 

  producers must collect their 2024 data and report it by 1 April 2025.

  YouFind mustout report: if you’re a small or large organisation, and what this means.

  If you have all the data under the new rules for 2024, you should report it in 2 batches: 

  • packagingreport activityyour data 
  • packagingdata classfor data 1 January to 30 June from 9 August 2024
  • packagingreport materialyour anddata weightfor data 1 July to 31 December from January 2025

  YouIf you do not needhave to: all the data required under the new rules, you should still report in 2 batches. In England, Scotland and Wales: 

  • do not report drinksany containersdata asrelating householdto andpackaging non-householdsupplied -between you1 needJanuary toand 30 March 2024
  • report data collected under the weightnew andrules numberfrom of1 unitsApril only 
  • splitto plastic30 intoJune ‘rigid’– do this from 9 August 2024 and ‘flexible’before packaging1 materialOctober -2024
  • report youyour just1 needJuly to report31 itDecember asdata ‘plastic’ from 1 January 2025 

  AllThe theenvironmental differencesregulators arewill explaineduse inthe moredata detailyou’ve insubmitted to calculate the relevant3 sectionsmissing ofmonths this(January, guidance.   February and March 2024). 

  What

  If ‘establishedyou’re reporting 2 batches in theNorthern UKIreland, means’ 

  Anyou organisationshould isfollow establishedthese inrules, thebut UKyour iffirst thebatch registeredonly office,needs headto officerecord orand principalreport placedata ofcollected businessunder the new rules from 1 May 2024. This is inbecause the UK.  legislation came into force later in Northern Ireland. 

  AnAll organisationthe candata alsoyou ‘establishedsubmit inmust follow the UK’new ifrules itfor justdata hasfrom a2024. branchThis orapplies postalto addressall innations. 

  The thedeadlines UK.for Thisreporting can be:  are:

  • a1 POOctober box 
  • an2024 office 
  • ato warehouse report for January to June 2024
  • domestic1 premisesApril that2025 areto usedreport for business July to December 2024 

  What data you need to collect 

  ThisYou ismust truecollect evendata ifabout the registeredpackaging office,you’ve headsupplied officewithin orthe principalUK placemarket ofor businessimported isinto outside the UK.   UK. 

  Reporting deadlines 

  LargeThe anddata smallyou producerscollect must reportinclude theirthe 2024following datacategories: 

  • packaging byactivity 1– Aprilfor 2025. 

    Readexample, moresupplying guidanceunder aboutyour reportingbrand, datespacking andor deadlinesfilling, or importing

  • packaging type – for largeexample, andif smallthe producers,packaging andis whathousehold toor donon-household
  • packaging ifclass you– misswhether athe reportingpackaging deadline. 

    Reportingis nationprimary, ofsecondary, saleshipment dataor tertiary

  • packaging material and self-managedweight 

  Some organisationorganisations wastemay foralso 2024need to 2026 

  Thecollect environmentalnation regulatorsdata. haveThis issuedis ainformation statementabout onwhich nation ofin salethe dataUK packaging is supplied in and datawhich nation in the UK packaging is discarded in. You can find out more about self-managedthis organisationin waste.  {:#rps} 

  Thisthe only‘Check appliesif you need to report nation data’ section of salethis dataguide. 

  Reporting andyour data 

  Report your data aboutby self-managedsubmitting organisationa waste.file Itusing doesthe not‘report applypackaging data’ service. 

  Find out how to anycreate otheryour EPR for packaging data youfile. 

  Large organisations need to report data every 6 months. 

  Small organisations must collect data for EPR2023 forand packaging.2024 and report their 2024 data by 1 April 2025.

  ReadFind theout regulatoryif positionyou’re statementa tosmall understandor howlarge thisorganisation, affectsand yourwhat datathis submission.means. 

  ReportPackaging packaging activity data  data 

  AsYou aneed largeto ortell smallus producerwhat youyour mustrole reportwas howwhen you suppliedimported packaging within or tosupplied the UKpackaging marketin under the followingUK. categories You –do youthis canby reportbreaking datadown underyour moredata thaninto onethe categorydifferent ifpackaging thisactivities. applies: These are: 

  • supplied under your brand brand
  • packed or filled  filled
  • imported (or as ‘first UK owner’) owner’)
  • supplied as empty (for example, if you’re a distributor) 
  • hired or loaned (service provider) 
  • supplied through an online marketplace that you own 

  Some organisations that supply packaged goods to the UK market may need to collect ‘nation data’. You can find out more about this in the ‘Check if you need to report nation data’ section of this guide. 

  ‘Supplied 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.  

  ‘Supplied under your brand’ packaging  packaging 

  This includes any packaged goods supplied under a brand that you own. A brand includes any of the following: following:

  • a name name
  • a trademark trademark
  • any distinguishing mark mark

  This applies to all filled packaging, where one or more of the pieces of packaging displays the brand you own. 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.   category.  

  Primary, secondary, shipment and tertiary packaging can all be classed as ‘supplied under your brand’ packaging.    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 supplied under your own brand. This is the case even if you paid or licensed another organisation to:  to: 

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

  If you have allowed another organisation usesto use your brand under a licence agreement, then you are responsible for the branded packaging they supply in the UK.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. packaging.

  For packaging with more than one brand  

  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.  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. 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.  packaging. 

  There are detailed illustrations and examples in the ‘agreed positions and technical interpretations’ guidance, produced by the environmental regulators.regulators. 

  There Versionare 52 isversions currentlyof this document, both stored on the National Packaging Waste Database. : 

  • for data submissions for 2023, check version 3
  • for data submissions from 2024 onwards check version 5 

  ‘Packed or filled’ packaging packaging for 2023 data 

  ReportIf anyyou pack or fill unbranded packaging that you packown, you should report it in this category. This could be for goods you packaged for your own organisation or fill.  for another organisation. 

  ‘Packed or filled’ packaging for data from 2024 

  YouFrom 2024, you should report branded packaging that you’ve packed or filled if all the following are true:  true: 

  • there’s only a packaging manufacturer’s brand on the packaging packaging
  • the brand does not relate to the product inside 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.  bags. 

  YouFrom 2024, you should also report branded packaging that you’ve packed or filled if either of the following are true:  true: 

  • the brand on the packaging belongs to an organisation that is not established in the UK UK
  • the brand on the packaging belongs to a UK organisation that is not a large organisation 

  Keep reporting any unbranded packaging you pack or fill. 

  ‘Imported’ packaging 

  YouThis mustincludes reportsome filled or unfilled packaging that you have imported and gone on to supply or discard in the UKUK. if:The  packaging you must report is: 

  • it’sany packaging that’s unbranded after it’s imported imported
  • it’sany packaging that is branded but the brand owner is not established in the UK UK
  • it’sany packaging that is branded, but the brand owner is not responsible for the import import
  • any packaging you supply to an organisation in the UK that is not classed as a large organisation under EPR for packaging packaging
  • youany importfilled itor intounfilled thepackaging UK,you filledimport orinto unfilled,the UK and discard without supplying within the UK or exporting 

   YouIf you do not needknow whether an organisation counts as a ‘large organisation’, check the list of large producers who have submitted data to reportthe filledenvironmental regulators. The list will be regularly updated. You should also check with the organisation. 

  You will not be responsible for packaging asaround ‘imported’filled goods that you’ve imported if it’s:  they are: 

  • branded, and you’ve imported itthem on behalf of a brand owner that is established in the UK and is a large organisation organisation
  • unbranded, and you go on to supply itthem to a large organisation that applies its brand to them before supplying them on 

  TheSee largethe organisationsection must‘Packaging reportclass thesedata’ ason ’suppliedthis underpage yourfor ownmore brand’. information about primary, secondary, tertiary and shipment packaging. 

  IfThere youare dodetailed notillustrations knowand whetherexamples anin organisationthe counts‘agreed aspositions aand ‘largetechnical organisation’,interpretations’ checkguidance, produced by the listenvironmental regulators. 

  There are 2 versions of largethis producersdocument, both stored on the National Packaging Waste Database: 

  • for whodata havesubmissions submittedfor 2023, check version 3
  • for data tosubmissions thefrom environmental2024 regulators.onwards Thecheck listversion will5 

  Imported bepackaging regularlyfrom updated.2024: Youunfilled shouldpackaging 

  In also2023, check‘imported’ withonly thecovered organisation.  imported filled packaging. 

  ThereFrom are2024, detailedsome illustrationsunfilled andpackaging examplesis aboutcovered importingtoo. inIf theunfilled ‘agreedpackaging positionsis imported and technicalthen interpretations’discarded guidance, produced by the environmentalimporter, regulators.report Versionit 5as an importer. 

  If this unfilled packaging is currentlybranded, storedresponsibility depends on who imported it: 

  • if the Nationalbrand Packagingowner Wasteis Database.  
    responsible for importing it, they must report it as ‘supplied under your own brand’
  • if the brand owner is not responsible for importing it, the importer must report it as ‘imported’ 

  ImportingImported packaging:packaging from 2024: secondary and tertiary packaging 

  IfFrom 2024 if you import filled branded packaging, you do not have to report secondary and tertiary packaging if all the following are true:  true: 

  • it is branded branded
  • the brand owner is a large organisation, established in the UK UK
  • the brand owner is responsible for the import import

  See

  Imports thepacked sectionby ‘PackagingUK classthird data’parties: onchanges this page for more2024 information about primary, secondary, tertiary and shipment packaging.   

  data 

  Packaging

  For that’s2024 packeddata, oryou’ll filled by UK third parties 

  You’ll also have to report if your organisation sells products to end usersconsumers where the following are true:  true: 

  • the brand owner is an overseas business that is not established in the UK 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 product
  • the overseas brand owner owns the packaging while it’s being filled and before you purchase it it  

  You are ‘first UK owner’ of these packaged products. Report this packaging under the ‘imported’ packaging activity. 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.  packaging. 

  ‘Supplied through an online marketplace that you own’ packaging  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.  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.  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.  data. 

  Find out how to create and submit your methodology.  . 

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

  ‘Hired or loaned’ packaging  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. 

  ‘Supplied as empty’ packaging  packaging 

  DistributorsThis whoincludes manufactureempty packaging that you’ve manufactured or importimported unfilledand (brandedthen supplied to an organisation that is not classed as a large organisation. 

  If you make or unbranded)import empty packaging mustand sell that to a large organisation, you do not need to report itthat aspackaging ‘suppliedunder EPR for packaging, but you do need to keep a record of it. 

  ‘Supplied as empty’empty’: unlesschanges for 2024 

  If you make or import empty packaging and sell that to a large organisation, you will have to report the packaging tounless a: you can show both the following are true: 

  • the large UKorganisation producer who fills or packs it  the packaging
  • the large UKorganisation brandthen ownersupplies -it whoto fillsanother itorganisation  

  Additionally, you will not have to formreport partthe ofpackaging if you can prove that once it is filled it will be reported by a brandedlarge salesorganisation unit that either:

  • is the brand owner
  • packed or filled the packaging

  YouIf canyou checkdo ifnot theknow whether an organisation you’recounts sellingas toa is‘large onorganisation’, check the list of large producers who have submitted data to the environmental regulators. regulators. The list will be regularly updated. You should also check with your organisation. 

  ReportPackaging packaging type data 

  You also need to tell us what type of packaging you supply. 

  Large producersorganisations will need to report whether the packaging:  packaging: 

  • is household
  • is or non-household non-household
  • commonly ends up in public bins bins
  • is a household or non-household drinks container container
  • is reusable reusable
  • becomes self-managed waste waste

  Small producersorganisations need to report:  collect: 

  • thetheir total packaging weight, excluding drinks containers
  • drinks containers  

  Household and non-household packaging for 2023 data 

  You must submit the weight of wastepackaging that is: 

  • household
  • non-household 

  Household packaging 

  You should class the following packaging as household: 

  • primary packaging
  • shipment packaging  

  If you supply primary or shipment packaging to a business which supplies it on to another business or an end-consumer, with any packaging included, all packaging should be reported as household packaging. For example, you may supply packaging to a business through a third party such as a distributor or wholesaler. 

  If you have clear evidence that you supply some of your primary and shipment packaging directly to a business that is the end user of all the packaging, excludingyou drinksdo containers not need to report it in this category. Keep records so that you can prove this. 

  Non-household packaging 

  You should class the following packaging as non-household: 

  • secondary packaging
  • tertiary packaging

  You should also class primary or shipment packaging as non-household packaging if you supply it to a business which is either of the weightfollowing: 

  • the andend-consumer numberof the goods contained in the packaging
  • an organisation that supplies the goods to an end-consumer with all of householdthe drinkspackaging containersremoved 

  You need to be able to show evidence of this. If you cannot, you must class this packaging as household. 

  How to provide evidence that something is non-household packaging 

  The environmental regulator will review the evidence that you’ve kept to support your assessment that the packaging is non-household. 

  Use the evidence listed here as a guide to support your assessment. 

  You’ll need to keep this evidence for at least 7 years. 

  Evidence for specialist goods that are for business use only 

  This applies to bespoke or specialist goods where the end-consumer could only be a business. The end-consumer is also your customer. 

  In this case, your evidence could include: 

  • bespoke product specifications
  • invoices (with VAT numbers to evidence business accounts)
  • customer contacts 

  Evidence for service or maintenance contracts 

  This applies to products that are part of a direct supply arrangement. For example, an organisation may supply a product as part of a service agreement. 

  In this case, your evidence could include: 

  • service contracts
  • stock replenishment reports 

  Other evidence 

  In addition to the evidence listed you may use customer confirmations as a source of evidence. A customer confirmation may help demonstrate that your direct business customer is the end user of the primary and shipment packaging, or they do not supply it on to anybody else. 

  You may be able to use customer confirmations if you aren’t able to provide any of the evidence listed. 

  This evidence could include: 

  • supply contracts
  • written customer confirmations (making it clear that the customer you supplied the packaging to is the end user) 

  Household and non-household packaging  

  packaging for data from 2024 onwards 

  There is separate guidance on how to assess household and non-household packaging.   for data from 2024 onwards. 

  Packaging that commonly ends up in public bins  

  bins 

  You must collectsubmit and report data about the material and weight of household packaging that commonly ends up in public bins. To do this, you should collect data about any of the followingpackaging in the list of ‘items that commonly end up in public bins’. 

  For any packaging in this category, you only need to report it in this category. You should not report it as household packaging as well. 

  This is the full list of items that commonly endsend up in public bins: 

  • packaging provided to consumers with take-away food or drink, including wraps, boxes, cups, cup-holders, bags and paper paper
  • packaging on confectionery, where the confectionery weighs less than 230g, including chewing gum packaging and chocolate wrappers wrappers
  • packaging on cigarettes, cigars, tobacco, e-cigarettes and vaping refills 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 60g
  • packaging on single portions of food which can be consumed immediately without further preparation, including sausage rolls, sushi, sandwiches, biscuits and individual cakes cakes
  • cartons holding 850ml or less of drink, whose contents can be consumed immediately without dilution 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.  year. 

  There are detailed illustrations and examples in the ‘agreed positions and technical interpretations’ guidance, produced by the environmental regulators.regulators. 

  There Versionare 52 isversions currentlyof this document, both stored on the National Packaging Waste Database.  : 

  • for data submissions for 2023, check version 3
  • for data submissions from 2024 onwards check version 5 

  DrinksChanges containers  for 2024 reporting 

  Straws should no longer be included in items that end up in public bins. They are not packaging – you do not have to report them.  

  You should still report packaging around straws - for example, a paper or cellophane wrapper. 

  Drinks containerscontainers 

  You includemust 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 supplied in England, Wales and Northern Ireland. 

  You only need to report drinks containers in this category. You do not need to report them in household packaging too. 

  For data from 2024 onwards, you must also collect and report data on drinks containers that are supplied in Scotland. 

  What’s classed as a drinks container? 

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

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

  Drinks containers should hold 150ml50ml to 3l of liquid. This includes containers that are 50ml to 3l and supplied in multipacks.  multipacks. 

  Takeaway cups do not count as drinks containers.  containers. 

  Reporting

  Drinks containers: reporting lids, labels and other parts 

  parts in 2023 and 2024 

  If the drinks container has other parts made of different material, like a lid or a label (also known as ‘ancillaries’), reportthere these: are different rules for 2023 data and 2024 data. 

  • For 2023, you should report these other parts separately, as primary household packagingpackaging. 

    For fordata glassfrom drinks2024 containers 

  • asonwards, partonly ofreport the totalother weightparts of theglass containerdrinks forcontainers separately, as primary household packaging. For steel, aluminium and PET drinkscontainers, containers include -the reportother parts in the total weight. Report the drinks container as whatever material makes up most of the weight 
  weight. 

  How large organisations should reportcategorise drinks containers data 

  You must split your drinks containers data into 2 categories:  categories: 

  • household drinks containers containers
  • non-household drinks containers 

  ThereRead isthe separate‘household guidanceand onnon-household packaging’ section to understand how to assessdo householdthis. 

  Most anddrinks containers will fall into the ‘household drinks containers’ category, because they’re supplied to non-business consumers. 

  If you believe you supply non-household packagingdrinks .  containers, you will need to provide evidence that this is the case. 

  How small producersorganisations should reportcategorise drinks containers data 

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

  Reusable packaging 

  LargeYou organisationonly 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:  categories: 

  • reusable packaging that is primary packaging packaging
  • reusable packaging that is non-primary packaging 

  Self-managedReporting reusable packaging waste for 2023 data 

  LargeFor organisationsreusable packaging, you should report self-manageddata wastein line with the rest of your packaging data (which will be either from 1 January or 1 March). If you do not have all of the required data for reusable packaging from either of these dates, you should report from 1 July 2023. 

  As well as either:  reporting it in this separate category, you should also make sure any reusable packaging is included in the household and non-household packaging that you report. When you do this, you can only report from 1 January and 1 March. 

  Reporting reusable packaging for data from 2024 onwards 

  Report your reusable packaging data in line with the rest of your packaging data. 

  Self-managed packaging waste 

  There are 2 things you need to report in the category of self-managed waste: 

  • consumer waste – such as waste you collect through a front of store take-back scheme to offset your household packaging 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 

  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.  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.  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.  data. 

  Self-managed consumer waste 

  Self-managedIf you’re a large organisation, 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.  fee. 

  You will need to report the total weight, broken down by material type. You must have evidence that it has been recycled.  recycled. 

  There are 2 different types of self-managed consumer waste:  waste: 

  • recovered packaging waste that is not commonly collected by local authorities authorities
  • reusable packaging waste that’s been reused at least oncewaste 

  Add these together when you report your self-managed consumer waste.  waste. 

  Recovered packaging waste that is not commonly collected by local authorities 

  You will need to report data about any packaging waste thatrecovered you’ve collected from consumers that you collect through a self-managed recycling scheme.  scheme. 

  Examples of these schemes include:  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.  authorities. 

  If you recover waste from consumers that is commonly collected by local authorities, you should report this as ‘self-managed organisation waste’.  waste’. 

  Items that are commonly collected by local authorities for recycling 

  The items that are commonly collected in all UK countries for recycling are:  are: 

  • aerosols aerosols
  • bottles and jars jars
  • brown envelopes envelopes
  • cardboard sleeves sleeves
  • cereal boxes boxes
  • corrugated cardboard cardboard
  • detergent and household cleaner bottles bottles
  • drinks bottles bottles
  • drinks cans cans
  • egg boxes boxes
  • foil trays trays
  • food pots and tubs tubs
  • food tins tins
  • fruit and vegetable punnets punnets
  • margarine tubs tubs
  • milk bottles bottles
  • toilet roll tubes tubes
  • toiletries and shampoo bottles bottles
  • plastic trays trays
  • window envelopes envelopes
  • yoghurt pots 

  In England, local authorities also commonly collect for recycling:  recycling: 

  • foil foil
  • shredded paper 

  In Northern Ireland, local authorities also commonly collect for recycling:  recycling: 

  • Tetra Pak and liquid food and drink cartons 

  In ScotlandScotland, and Wales, local authorities also commonly collect for recycling:  recycling: 

  • foil foil
  • lids from glass jars jars
  • shredded paper paper
  • Tetra Pak and liquid food and drink cartons 

  In Wales, local authorities also commonly collect for recycling: 

  • foil
  • lids from glass jars
  • shredded paper 

  Reusable packaging waste 

  This is waste from packaging which:  which: 

  • has been designed to be re-used and refilled multipleat times least once
  • is now no longer being used as packaging - it has become waste 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.  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.  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.  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.  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.  on-site. 

  This could include ‘backhauling’ or where you’ve arranged for packaging waste to be removed by a private contractor.  contractor. 

  This can include:  include: 

  • your own branded packaging waste 

    waste
  • other brands’ packaging waste waste
  • packaging waste you’ve received from another organisation for ‘backhauling’ ‘backhauling’
  • unbranded packaging waste 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.  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 

  ReportPackaging packaging class data 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. items.

  For example, if you sell peas in steel tins with paper labels, the primary packaging is ‘steel tin’ and ‘paper label’.  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.  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. 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’.  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. 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. 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. chain.

  Tertiary packaging does not include road, rail, ship and air containers. 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’.  pallet’. 

  ReportPackaging packaging material and weight data 

  SmallAfter andyou’ve largecategorised producersyour mustdata reportinto the weightrelevant inpackaging kilogramsactivities, (kg)you must report the weight of the individual materialsmaterials. 

  The forpackaging eachmaterial packagingweight activityshould yoube carrygiven out.  in kilograms (kg). 

  Types of material 

  You should reportcategorise your data forby the following materials:  materials: 

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

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

  • bamboo bamboo
  • ceramic ceramic
  • copper copper
  • cork cork
  • hemp hemp
  • rubber rubber
  • silicone 

  You must report each material type separately.  separately. 

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

  Composite and multi-material packaging 

  Composite packaging is made of:  of: 

  • 2 or more layers of different materials 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). most).

  For example, a crisp packet contains plastic and foil. The main material is plastic, so you should report this as plastic.  plastic. 

  You should class a material as ‘fibre-based composite’ if both of the following are true:  true: 

  • the main material contains paperboard or paper fibres fibres
  • the material is laminated with plastic 

  It may also have layers of other materials.  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.  hand. 

  For this sort of packaging, you should record the weights of the different materials separately.  separately. 

  RecordCheck recyclabilityif data 

  Fromyou 1need Januaryto 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 will submit their data for the whole of 2025 by 1 April 2026.  

  Find out more by reading: 

  • an overview of the RAM that explains the process  
  • how to assess and rate individual materials - use this to find red, amber or green ratings for your packaging materials 
  • definitions and background - this explains the stages of recyclability and some technical terms 

  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.  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 

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

  • supply filled or empty packaging to customers in the UK, where they are the end user of the packaging packaging
  • supply empty packaging to UK organisations that are either not legally obligated, or are classed as a small organisationproducer organisation
  • hire or loan out reusable packaging packaging
  • own an online marketplace through which organisations based outside the UK sell their empty packaging and packaged goods to UK consumers 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.  it. 

  Supplying packaging includes:    includes: 

  • selling selling
  • hiring hiring
  • loaning loaning
  • gifting gifting
  • providing in exchange for something other than money money
  • providing because of a statutory duty 

  This also includes packaging that you’ve imported and then discarded.  discarded. 

  How to report your data 

  Report your data by submitting a file using the ‘report packaging data’ service.  

  Find out how to create your EPR for packaging data file.  

  Read guidance about when large and small producers need to report data. 

  How parent companies should report data  

  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.  separately. 

  You do not need to include data for any of your subsidiaries that have registered independently.  independently. 

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

  There are detailed illustrations and examples in the ‘agreed positions and technical interpretations’ guidance, produced by the environmental regulators.regulators. 

  There Versionare 52 isversions currentlyof this document, both stored on the National Packaging Waste Database. : 

  • for data submissions for 2023, check version 3 
  • for data submissions from 2024 onwards, check version 5

  How your data will be used  used 

  Your data is used to work out your waste management fee and your recycling obligations.  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:  your: 

  • household packaging data data
  • packaging that commonly ends up in public bins data 

  Packaging data that’s been reported under the 2007 regulations (‘transitional reporting’) 

  regulations 

  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. This does not discount any waste disposal fees.  .  

  ThisYou’ll ishave alsoto knownbe asable theto ‘dualprovide reporting’evidence orthat ‘transitional reporting’ provision.  

  If you have submitted packaging under the 2007 regulations, met your recycling obligationsobligation onhas thisbeen andmet wantfor theany discountpackaging tothat be applied to your obligations for 2025, you mustwant calculate the amount to bediscount discountedunder and submit this as part of your 2024 packaging data.   provision.  

  ThisYou’ll onlyreport appliesthis data to large organisations. 

  There are detailed illustrations and examples in the ‘agreedregulators positionsseparately and- technicaldo interpretations’not guidance,make producedyour byown thedeductions environmentalwhen regulators.reporting Version 5 is currently stored on the National Packaging Waste Database. data.  

  How to calculate the discount 

  YouGuidance mustwith multiplymore twodetails, figures.  

  First,including thehow 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 2007regulators, regulations.will Thesebe arepublished thelater 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%.  year.

  You’llFor haveexample, toan 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%.   48%. 

  The manufacturer, convertor and packer would collect the data in 2023 and report it in 2024, under the 2007 regulations.regulations.The The seller’s obligation (48%) would not come under the 2007 regulations because it was supplied in 2024.    2024.  

  In 2024 an organisation suppliesbecomes theobligated same packaging under EPR for packaging.packaging The large organisation will have a recycling obligation in 2025 for 100% of the same item of packaging when it is supplied in 2024.  the UK.  

  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%.  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 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.  data. 

  Example 1: Imported supermarket groceries  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.  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.  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.  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.  company. 

  After a consumer has bought broccoli, they remove the plastic film and label and put it into their bin.  bin. 

  Who needs to collect data?  

  data? 
  • the wholesaler wholesaler
  • the supermarket supermarket
  • the hiring company 

  Packaging material they should record  

  record 
  • shrink wrap wrap
  • reusable plastic trays trays
  • plastic film protecting the broccoli broccoli
  • labels 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.  reused. 

  Data the wholesaler should collect  

  collect 

  The wholesaler needs to report the shrink wrap and the reusable plastic boxes.  boxes. 

  They should record the following information for the shrink wrap:  wrap: 

  • packaging activity: packed or filled as unbranded unbranded
  • packaging type: non-household non-household
  • packaging class: tertiary packaging 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.  boxes. 

  First data entry:  entry: 

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

  Second data entry:  entry: 

  • packaging activity: packed or filled as unbranded unbranded
  • packaging type: reusable reusable
  • packaging class: non-primary packaging packaging
  • packaging material and weight: plastic 

  Data the supermarket should collect  

  collect 

  The supermarket needs to report the plastic film protecting the broccoli and the labels that have the supermarket’s brand on them.  them. 

  They should record the following data for the plastic film:  film: 

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

  They should record the following data for the labels:  labels: 

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

  Data the hiring company should collect  

  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.  pallets. 

  First data entry:  entry: 

  • packaging activity: hired or loaned loaned
  • packaging type: non-household non-household
  • packaging class: tertiary packaging packaging
  • packaging material and weight: wood 

  Second data entry:  entry: 

  • packaging activity: hired or loaned loaned
  • packaging type: reusable reusable
  • packaging class: non-primary packaging packaging
  • packaging material and weight: wood 

  Example 2: Heat pumps made abroad  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.  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.  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.  installer. 

  The installer removes all the packaging and recycles it. The installer does not send any of the packaging back to the engineering organisation.  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.  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.  shelves. 

  They sell the heat pumps in their cardboard boxes. Some go directly to consumers, and some to heat pump installers.  installers. 

  The installers and consumers remove the cardboard boxes and recycle them.  them. 

  Who needs to collect data?  

  data? 

  The engineering organisation is the only one who needs to report data, in this instance.  instance. 

  Who does not need to collect data?  

  data? 

  The trade outlets and the heat pump installers do not need to report.  report. 

  Data the engineering organisation should collect  

  collect 

  The engineering organisation needs to collect data about the following packaging materials:  materials: 

  • cardboard boxes boxes
  • pallets pallets
  • shrink wrap wrap
  • plastic wrap 

  They should collect the following data for the cardboard boxes:  

  boxes: 
  • packaging activity: supplied under your brand brand
  • packaging type: household household
  • packaging class: primary packaging 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:  entry: 

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

  Second data entry:  entry: 

  • packaging activity: packed or filled as unbranded unbranded
  • packaging type: reusable reusable
  • packaging class: non-primary packaging packaging
  • packaging material and weight: wood 

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

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

  They should collect the following data for the shrink wrap:  wrap: 

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

  They should collect the following data for the plastic wrap:  wrap: 

  • packaging activity: packed or filled as unbranded unbranded
  • packaging type: household household
  • packaging class: primary packaging 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 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  feedback 

  If you have any questions, contact the packaging team.  team. 

  Email: packaging@defra.gov.uk   

  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. .