GovWire

If your organisation is affected by EPR for packaging, you will need to report your packaging data.

Find out if you need to report packaging data.

This guidance applies to England, Northern Ireland, Scotland and Wales.

When to collect and report your data for 2023

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

If you do not have all the required data recorded from 1 January, you must report all of your data from the 1 March 2023. If you report data that covers a period starting from 1 March, this will be used to calculate a full years worth of data.

Large organisations in Wales should comply with this reporting schedule if they have the required data. If they do not have the required data, they should start collecting data from the date the regulations come into force in Wales in mid-2023 and submit it between 1 January 2024 and 1 April 2024.

Small organisations in Wales should comply with this reporting schedule if they have the required data. If they do not have the required data, they should start collecting data from the date the regulations come into force in Wales from mid-2023 and submit it between 1 January 2024 and 1 April 2024.

What data you need to collect

You must collect data about the packaging youve supplied through the UK market or imported into the UK.

The data you collect must include the following categories:

• packaging activity this is how you supplied the packaging
• packaging type for example, if the packaging is household or non-household
• packaging class - whether the packaging is primary, secondary, shipment or tertiary
• packaging material and weight

You may also need to collect nation data. This is information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in.

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.

You must report your data by submitting a file using the Report packaging data service.

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

Packaging activity data

You need to tell us what your role was when you supplied the packaging in the UK. 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

If you supply packaged goods to the UK market you may need to report nation data. You can find out more about this in the check if you need to report nation data section.

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 name
• a trademark
• any distinguishing mark

This applies to all packaging that contains goods, where one or more of the pieces of packaging display your brand.

Primary, secondary, shipment and tertiary 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 or licensed another organisation to:

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

For packaging with more than one 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 packaging.

If a sales unit contains packaged items with another organisations brand, you should only collect data for the packaging youve added to the item that has your brand on it, and any other unbranded packaging.

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 packaging around goods that you have imported and gone on to supply or discard in the UK. If you import goods into the UK, the packaging you must report is:

• secondary and tertiary 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
• any packaging you import into the UK and discard without selling or exporting

You will not be responsible for packaging around filled goods that youve imported if they are:

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

See the section Packaging class data on this page for more information about primary, secondary, tertiary and shipment packaging.

Supplied through an online marketplace that you own packaging

Under EPR for packaging, youre 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.

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 in the UK.

You must also send a description of the methodology youve used to collect your data to the relevant environmental regulator before submitting your first set of data. We will let you know more about this process soon.

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

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 as empty packaging

This includes empty packaging that youve manufactured or imported and then supplied to an organisation that is not classed as a large organisation.

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.

Packaging type data

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

Large organisations will need to report whether the packaging:

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

Small organisations need to report:

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

If youre a small organisation you do not need to break down your data into the other packaging types.

Household and non-household packaging

You must submit the weight of packaging that is:

• household
• non-household

Whats classed as household packaging?

Y

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