GovWire

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

Youll need to collect data about the packaging youve 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 youre 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 thats supplied under your own brand. This is the case even if you paid another organisation to:

• produce goods that youve gone on to sell under your brand name
• pack goods that youve 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 its 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 youll need to report is:

• transit packaging
• secondary packaging that does not fall under the supplied under your brand packaging activity
• any packaging thats unbranded when its 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 youve 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 its 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 youve 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

Youll also need to tell us what type of waste the packaging is likely to become when its 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.

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