Guidance

Check what to report for EPR for packaging as a large producer

This guidance explains your reporting responsibilities as a large producer under extended producer responsibility (EPR) for packaging. It explains how to identify what data you must report and understand which obligations do not apply to you.

• From: Department for Environment, Food & Rural Affairs, Environment Agency and PackUK
• Published: 24 November 2022
• Last updated: 19 August 2026 — See all updates

A large producer is an organisation that: 

• has an annual turnover of more than £2 million 

• is responsible for supplying more than 50 tonnes of packaging in the UK 

If you are below these thresholds, you should check if you are a small producer under EPR for packaging.

There is separate guidance on what small producers must report.  

How to use this guidance 

This guidance will help you understand your reporting obligations within the Report packaging data (RPD) service.  

It uses the same terminology that you will find in the RPD service, which will help you identify which information belongs in each column of the packaging data file you upload to report your data. The data file is a comma-separated values (CSV) file, similar to an excel spreadsheet. 

Step 1: identify which packaging activities your organisation carries out 

You must report how you supply packaging in the UK. Supplying means: 

• selling, hiring or loaning packaging 

• exchanging packaging for something other than money  

• providing packaging due to a statutory function 

• providing packaging as a prize or gift 

• importing packaging and then discarding it 

How you supply packaging is called a ‘packaging activity’ under EPR for packaging. You must identify your packaging activities before moving on to step 2: assess what your packaging is made of and how much it weighs. 

There are different categories of packaging activity, and your organisation may be involved in more than one packaging activity at any time: 

• supplying under your brand  

• packing or filling 

• importing  

• supplying as empty  

• hiring or loaning  

• supplying through an online marketplace 

You must record nation data if you sell filled packaging direct to an end user (business or consumer) even if you do none of the other listed packaging activities. 

Read the reporting nation data section for more details. 

Packaging activity: supplying under your brand 

You must report packaging as ‘supplied under your brand’ if it is filled, and has your brand name, trademark or other distinguishing mark on it. This applies when: 

• you import it yourself 

• you supply the filled packaging where one or more packaging components displays your brand 

• you pay another organisation to import your filled branded packaging into the UK 

• another organisation manufactures or packs goods that will be sold in the UK in your filled branded packaging 

• you license another organisation to manufacture and supply your filled branded packaging in the UK  

As an example, you may supply filled packaging, like a ready meal, inside an unbranded plastic tray with film, with a cardboard sleeve carrying your brand. In this instance, the cardboard sleeve, the plastic tray and film should be included as part of the data you report under the brand activity. 

If you add a new branded packaging component to a product and its packaging that has been supplied by another organisation with their brand on it, you are only responsible for reporting the new branded component (such as a label). 

If the new packaging component is unbranded you must report this as ‘packed or filled’. 

If packaging displays more than one brand: 

• the brand owner who is the first producer in the UK that supplies the filled packaging, must report it 

• and none of the brand owners made the first supply, the owner of the brand that occupies the largest area on the packaging must report it 

What you must not report as ‘supplied under your brand’ 

Do not report any: 

• packaging on your branded goods if they’re imported and you are not responsible for the import 

• unfilled branded packaging with your brand 

Read examples on when you do and do not report under ‘supplied under your brand’ in sections 16, 26 and 27 in the ‘agreed positions and technical interpretations’ guidance on the National Packaging Waste Database. 

Packaging activity: packing or filling 

You must report branded and unbranded packaging as ‘packed or filled’ under the following circumstances. 

Unbranded packaging 

You must report any unbranded packaging you pack or fill for your own or another organisation to supply. 

Branded packaging 

You must report branded packaging that you’ve packed or filled if the packaging manufacturer’s brand is only on the packaging, and it relates only to the packaging, not the product. 

For example, if you pack or fill a branded bag and the brand on the bag relates to the manufacturer of the bag and not to the product inside, you must report the bag under the ‘packing or filling’ activity. 

You must also report branded packaging that you’ve packed or filled if either of the following are true:  

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

• the brand on the packaging belongs to a UK organisation that is not a large producer 

Packaging activity: importing 

You must report imported packaging as ‘imported’ if it’s filled and: 

• you then supply it on to another organisation 

• you discard in the UK 

• it’s unbranded or not your brand, and you are responsible for the import 

• it’s branded, and the brand owner is responsible for the import but is not a large producer or is not established in the UK 

• you are the first organisation in the UK to take ownership of the packaging 

• it’s unbranded, and remains unbranded after import 

If you import unfilled, branded or unbranded packaging and discarded it in the UK, you must report it as ‘imported’.

What you must not report as ‘imported’ 

Do not report filled packaging as ‘imported’ if it’s: 

• unbranded and you go on to supply it to a ‘large producer’ that applies its brand to it  

• branded and you’ve imported it on behalf of a brand owner who is a ‘large producer’ established in the UK - in this instance the brand owner is responsible for reporting under the ‘supplied under your brand’ activity 

If you import unfilled branded or unbranded packaging it must be reported as ‘packed or filled’ or as ‘supplied as empty’. 

Packaging activity: owning an online marketplace  

You must report any packaging where non-UK suppliers sell their goods into the UK through a website or app (online only) that you operate as ‘online marketplace’. 

You must also provide a description of the methodology you’ve used to collect the data you report. 

Find out how to create and submit your methodology. 

What you must not report as ‘online marketplace’ 

Do not report under this activity if you own a website that supplies goods from UK organisations only. 

If you also supply your own branded packaging on your online marketplace in the UK, this packaging should be reported under the ‘supplied under your brand’ activity and must not be reported twice. 

If you pack or fill unbranded packaging and supply this through your online marketplace in the UK, you must report this as ‘packed or filled’, not ‘online marketplace’. 

If you are an online marketplace, you do not need to report packaging class and do not need to read ‘step 3: identify the class of packaging’ in this guidance. 

Packaging activity: hiring or loaning 

If you hire out or loan unfilled packaging (also known as a service provider) to another organisation, such as wooden pallets, you must report it as ‘hired or loaned’. You only need to report this packaging the first time it is supplied. 

What you must not report as ‘hired or loaned’ 

Do not report packaging you hire or loan from another organisation for your own packaging activities. 

Packaging activity: supplying as empty 

If you supply empty branded or unbranded packaging (also known as a distributor), you must report it as ‘supplied as empty’ unless the packaging will become the responsibility of a ‘large producer’ who: 

• fills or packs it 

• fills it to form part of their branded packaging 

You can find out if a producer is a large producer by: 

• checking the public register to see who has registered with the environmental regulators 

• asking the organisation itself 

Read examples on how to evidence that a large producer is a packer or filler or brand owner in appendix 10 of version 8 of the ‘agreed positions and technical interpretations’ guidance on the National Packaging Waste Database.

Step 2: assess what your packaging is made of and how much it weighs 

For each packaging activity in step 1, you must report the packaging material and weight in kilograms (kg).  

You should assess the packaging material and weight of each component before moving on to step 3: identify the class of packaging. 

Packaging materials 

You must report data for the following materials: 

• aluminium, such as tins or bottle tops 

• fibre-based composite, such as liquid and non-liquid cartons  

• glass, such as bottles or jars 

• paper or card, such as cereal boxes or cardboard sleeves 

• plastic  

• steel, such as aerosols 

• wood, such as wooden pallets 

• other, such as bamboo, ceramic, copper, cork, hemp, rubber and silicone 

You must also report the plastic material sub-type (rigid or flexible) as either ‘rigid’ (such as a shampoo bottle), or ‘flexible’ (such as cling film) for household and commonly binned packaging. 

How to report separate components 

You must report the weight and material of each component separately, for example, the plastic blister in a multipack of batteries is distinct from the cardboard backing.  

PET, steel and aluminium drink containers 

For polyethylene terephthalate (PET) (a type of plastic), steel and aluminium drink containers, all components regardless of their material must be reported under the predominant material (the material that weighs the most). 

For example, a PET drink container with a paper label and a high-density polyethylene (HDPE) (another type of plastic) lid, would be reported as PET, including the weight of the paper label. 

Glass drink containers 

For glass drink containers you must report all components separately. 

Packaging components formed of integrated materials 

You must report the full weight of the packaging component in kg as the predominant material by weight (the material that weighs the most).  

For example, a: 

• crisp packet made of plastic and foil where the predominant material is plastic, must be reported as plastic 

• toothpaste tube made of plastic and aluminium where the predominant weight is plastic, must be reported as plastic 

Fibre-based composite 

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

• the packaging component contains paper or board or paper fibres with one or more plastic layers, forming a single unit that cannot be separated by hand 

• the plastic layers are more than 5% of the packaging material by mass – if it’s 5% or less, classify it as ‘paper or card’ 

Step 3: identify the class of packaging 

Under EPR for packaging, packaging class describes how packaging is used.  

For each packaging activity, you must report whether packaging is classed as primary, secondary, tertiary, or shipment. 

You must identify the class of packaging before moving on to step 4: confirm the types of packaging. 

If you are an online marketplace, you do not need to report packaging class. 

Primary packaging 

Primary packaging can be either: 

• packaging on a single item to sell to an end user (consumer or business), such as a bottle of wine 

• packaging on multiple items, such as a multipack of beans, that is intended as a single sales item to an end user 

The primary packaging includes all the packaging that contains and protects the item or items. 

Secondary packaging 

Secondary packaging is used for grouping several sales items (products and the primary packaging) together. Organisations may also use secondary packaging to display goods in shops, such as a cardboard tray. 

Tertiary packaging 

Tertiary or transit packaging is used for handling and transporting primary or secondary packaging, for example crates to prevent damage during transport. Tertiary packaging does not include road, rail, ship and air containers.  

Shipment packaging 

Shipment packaging is tertiary packaging on items that are supplied or intended to be supplied to a consumer (not a business). This includes packaging on goods sold online or delivered to the purchaser from a shop or collection point. Shipment packaging can include cardboard boxes, carrier bags, bubble wrap and mail bags. 

Step 4: confirm the types of packaging 

For each packaging activity, you must report whether the packaging: 

• is household or non-household packaging 

• commonly ends up in public bins 

• is a household or non-household drink container 

• is reusable 

• is self-managed – this is packaging waste that is handled by your own organisation 

You must confirm the types of packaging before moving on to step 5: check if you need to report recyclability data for your packaging. 

Packaging type: household and non-household packaging 

For each packaging activity, you must assess and report if your packaging is considered household or non-household packaging. 

Packaging type: commonly ends up in public bins 

You must report data about the material and weight of packaging that commonly ends up in public bins, such as: 

• packaging provided to consumers with take-away food or drink, including wraps, boxes, cups, cup-holders, bags and paper 

• packaging on confectionery, where the confectionery weighs less than 230 grams (g), including chewing gum packaging and chocolate wrappers 

• packaging on cigarettes, cigars, tobacco, e-cigarettes and vaping 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 

• packaging on single portions of food which can be consumed immediately without further preparation, including sausage rolls, sushi, sandwiches, biscuits and individual cakes 

• cartons holding 850 millilitres (ml) or less of drink, whose contents can be consumed immediately without 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 must 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. 

Packaging type: drink containers 

You must report drink containers that hold between 150ml to 3 litres of liquid as ‘drink containers’. This includes containers that are part of multipacks and single-use bottles or cans for drinks that are made wholly or mainly of: 

• PET plastic 

• glass  

• steel 

• aluminium 

You must report your drink containers as either: 

• household drink containers 

• non-household drink containers 

Read guidance on how to assess if your drink containers are considered household or non-household packaging. 

What you must not report as drink containers 

You must report the following drink containers as ‘primary packaging’ instead of ‘drink containers’: 

• containers under 150ml or over 3 litres 

• takeaway cups or HDPE drink containers, such as a milk bottle 

How to report drink container components 

For glass drink container components, you must report the weight of each component separately by material type as primary packaging (household or non-household). 

For steel, aluminium and PET drink containers, you must report individual components made of different materials, like a lid or a label, as part of the total weight of the steel, aluminium and PET. 

You must report the container under the material category that weighs the most (the predominant material).

Packaging type: self-managed waste 

Self-managed waste refers to packaging waste that you, as an organisation, take direct responsibility for managing yourself. This means you do not rely on local authorities to collect it for you. 

Report self-managed waste as either: 

• consumer waste 

• organisation waste 

Consumer waste 

For self-managed consumer waste, you must only report data for waste that has been recycled.  

You must: 

• report the total weight in kg, broken down by material type 

• evidence that the packaging has been recycled in the reporting period, not just sent for recycling – the evidence must come from an accredited reprocessor or exporter 

There are 3 different types of self-managed consumer waste: 

• packaging waste, such as flexible plastic packaging, that is not commonly collected by local authorities 

• reusable packaging that’s been reused at least once, for example, crates used to deliver goods are then collected back and used at least one other time 

• closed-loop packaging waste 

You must report packaging waste that’s not commonly collected and reusable packaging together under self-managed consumer waste. 

Closed-loop packaging waste is reported as a separate figure. 

Self-managed consumer waste data is used to offset packaging made of the same material that you’ve reported as household packaging and commonly binned. This will reduce your disposal fee. 

Organisation waste 

You must report data about all packaging waste that your organisation has collected. This could include ‘backhauling’ (using return delivery routes to collect and transport packaging waste back to your organisation) or where you’ve arranged for packaging waste to be removed by a private contractor. 

This can include: 

• your own branded packaging waste 

• other organisations (brand) packaging waste 

• packaging waste you’ve received from another organisation for ‘backhauling’ 

• unbranded packaging waste 

• packaging waste you’ve recovered from consumers that is commonly collected by local authorities 

The regulators have issued a statement on self-managed organisation waste.  

Packaging type: reusable packaging 

Reusable packaging has been designed to be reused and refilled multiple times, for example a wooden pallet for shipping goods. It must only be reported under the ‘reusable packaging’ category if it meets this definition and if the producer has created a system of reuse for the packaging. 

Report reusable packaging the first time you supply it. You must: 

• include the weight of reusable packaging when you report how much packaging you’ve supplied under the relevant packaging activity  

• report reusable packaging separately – you must split your data to show how much is primary and non-primary reusable packaging 

You should also report how much of your reusable packaging is household and non-household packaging. 

Step 5: check if you need to report recyclability data for your packaging 

You must report recyclability data for: 

• household packaging  

• packaging that commonly ends up in public bins 

• household drink containers made of glass 

You must use the recyclability assessment methodology (RAM) to assess recyclability and rate packaging as red, amber or green. 

RAM ratings affect your disposal fee.  

You must check whether you need to report RAM data before moving on to step 6: check if you need to record nation data. 

Step 6: check if you need to record nation data 

Nation data is information about which of the 4 UK nations the packaging is supplied and discarded in. This requirement is separate from other packaging data reporting requirements. 

The data must be broken down by weight in kg and material type. It does not need to be broken down by packaging class or type.  

Nation data does not: 

• impact recycling obligations 

• affect disposal fees 

The regulators have issued a statement on when to collect and report nation data.  Find out more about how nation data may affect your submission. 

Nation of supply 

Nation of supply is the nation in the UK where you have supplied packaging to (the destination). 

You should record nation of supply if: 

• you sell filled packaging direct to an end user (business or consumer) 

• you supply empty packaging as ‘supplied as empty’ and the large producer or brand owner is not responsible for it 

• your organisation hires out or loans packaging to other organisations  

• you own an online marketplace where packaging is supplied to the UK market from outside the UK 

Nation of supply packaging must only be recorded under one activity. If you sell filled packaging to an end user but you also carry out any of the other 3 packaging activities listed under ‘nation of supply’, you must only record it once.  

Nation of discard 

If you are an importer based in the UK who imports filled packaging into the UK for your own use, you should record the nation of discard. The nation of discard is the nation in the UK where you have discarded the packaging as waste.  

If you are not an importer, you must not record this data. 

Example of reporting nation of supply and discard 

A large producer based in England hires out and loans packaging and imports empty reusable pallets to hire out across the UK. These were first hired out (first supplied) to a customer in Scotland. The large producer should record the following under the ‘hired or loaned activity’: 

• the weight and material of the pallets under the hired or loaned activity 

• the nation of supply as Scotland 

The same producer discarded imported packaging at their English site so should record the following under the ‘importer activity’: 

• the weight and material of any transit packaging that was imported and discarded and any pallets damaged during import that they discarded at the site themselves 

• the nation of discard of the transit packaging and damaged pallets as England 

What to do next 

You must submit your packaging data using the RPD service. 

Read guidance to understand how to: 

• register to use the service 

• report your data – including the codes you need to use and how to create your CSV file

Get help or give feedback 

If you have any questions, contact your environmental regulator or the EPR for packaging customer service team.

Check contact details for regulators and administrators.

You can also give feedback about this guidance.

User panel

Defra is looking for waste and packaging professionals to join a user panel to help improve our services. Find out how to take part in resources and waste research sessions.

Published 24 November 2022

Last updated 19 August 2026 — Show all updates

1. 19 August 2026

   Guidance updated to improve clarity and usability. Updated information can be found in steps to help navigate what information you need to report.

2. 9 April 2026

   In 'Example 2: Heat pumps made abroad', added that the organisation should collect and report the weight of the shrink wrap in kilograms.

3. 7 April 2026

   In the section called 'Examples of how to collect and report data', we've clarified that organisations should collect and report the weight of packaging materials in kilograms (kg). We've also explained that, for plastics, large organisations should report the 'packaging subtype' as 'flexible'.

4. 23 March 2026

   In the 'Reporting packaging activity data' section, clarified that packaging data can only be reported under one packaging activity, not multiple packaging activities. Organisations must split their packaging data so they report each packaging activity separately.

5. 6 March 2026

   In the 'Plastic subtypes' section, removed the 'household drinks containers' bullet point because large producers do not need to split household drinks containers into ‘rigid’ and ‘flexible’ subtypes.

6. 3 March 2026

   Added information to the 'Importing packaging: secondary and tertiary packaging' section.

7. 17 February 2026

   An update collecting several minor fixes for accuracy. The reusable packaging section now explicitly states that reusable packaging must be reported twice. The hired or loaned section clarifies that it is the service provider who must report, not the person hiring or borrowing. The plastic subtypes section adds household drinks containers to the list of packaging types requiring a rigid and flexible split. The tertiary packaging definition has been corrected. The shipment packaging definition covers all tertiary packaging supplied to consumers, not just online or mail order. The section on packaging already supplied by another producer has been rewritten, using "supplied" rather than "reported" as the legal trigger. There are further minor fixes for style.

8. 4 February 2026

   This update aligns the guidance with the Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025, covering multi-brand packaging, adding components to packaging, closed-loop packaging waste, fibre-based composite and evidence requirements. It also adds information on enforcement powers, record-keeping, resubmission requirements. The update removes outdated content on the 2007 regulations transitional period and simplifies plastic/paper bag reporting to reference RPS 330. Various factual corrections include the online marketplace methodology deadline, small producer drinks container wording, and terminology changes ("waste disposal fee" not "waste management fee").

9. 16 December 2025

   Content updated to include information about reporting plastic and paper bags supplied in England and the Regulatory position statements issued by the Environment Agency and other UK nations. Information clarified on composite packaging and fibre-based composites.

10. 1 August 2025

    The environmental regulators have issued a statement on collecting and reporting data under the recyclability assessment methodology. This update provides links to that statement.

11. 19 June 2025

    Updating the section on small producers to add the 2 codes they must use, and to clarify under ##Data you must collect and report that they must record all drinks containers as 'household drinks containers' (which will now be consistent with the wording under ##Report packaging type data).

12. 19 May 2025

    Adding link to new small producers guidance.

13. 28 March 2025

    This update removed a reference to small producers ('organisations') reporting recyclability data. They do not have to report this data. It also corrects a typo - a reference to '50ml' drinks containers has been changed to 150ml

14. 24 March 2025

    This updates adds information to support small producers, removes references to data collected in 2023, links to the recyclability assessment methodology, adds guidance on transitional reporting and links to a regulatory position statement on reporting data. It also adds some terms like 'distributor' that were not previously used.

15. 17 October 2024

    A new edition of the regulators' ‘agreed positions and technical interpretations’ guidance has been published - this updates the version number where it is mentioned.

16. 15 August 2024

    This version updates dates and deadlines for reporting 2024 and 2025 data. It also clarifies a point about 'supplied as empty' packaging and corrects some minor omissions.

17. 31 July 2024

    Several small changes in this update: the start date for reporting on the 1 January to 30 June period has been updated from 1 July to 9 August 2024; Defra is looking for waste and packaging professionals to join a user research panel to help improve our services - a link to more information about how to take part has been added.

18. 9 July 2024

    Minor updates around deadlines and definitions for clarity, based on user research feedback. Updating definition of shipment packaging. Linking to the agreed positions guidance from the section on how parent companies should report data, for examples.

19. 14 May 2024

    Updated contact email address.

20. 2 May 2024

    Adding link to the newly published list of large producers on the report packaging data service.

21. 28 March 2024

    This change explains that the list of large producers on RPD will be published once the data is ready. It also clarifies the definition of shipment packaging.

22. 26 March 2024

    This updates references to the regulators' 'agreed positions' guidance. A new version has been published that covers data submissions from 2024 onwards.

23. 11 March 2024

    New reporting regulations come into force on 1 April that affect the packaging data some organisations must report. There are changes to several areas: - drinks containers - filling packaging - imported goods - what counts as household packaging - supplying empty packaging to large organisations - what packaging sellers are responsible for - transitional provisions for recycling obligations This update gives details on these changes.It also adds links to the environmental regulators' 'agreed positions' document.

24. 23 January 2024

    Specifying that the second data report should be made between 1 Jan and 1 April 2024, giving deadline for reporting for the first half of 2023, and explaining that no enforcement action will be taken for late submissions up to 31 May 2024.

25. 19 December 2023

    Including specific date from which to report data in Wales.

26. 18 October 2023

    We've added a link so that you can give feedback about this guidance.

27. 21 September 2023

    An update to match regulations: where packaging is decribed as 'imported, emptied and then discarded', that's been changed to 'imported and discarded' throughout.

28. 16 August 2023

    This adds a link to the report packaging data service, which has now gone live.

29. 6 June 2023

    Added Welsh translation

30. 17 March 2023

    We’ve changed the title of the guidance. We’ve made minor changes to the style, order and some terminology to make the guidance clearer and to reflect the fact that the regulations are now in force. We’ve clarified that this guidance applies to England, Scotland, Northern Ireland and Wales. We’ve added a new section titled ‘When to collect and report your data for 2023’. We’ve updated the names of the 4 different data categories. We’ve also updated the following sections to make them clearer: ‘Supplied under your brand’ packaging; ‘Imported’ packaging; Household and non-household packaging; Drinks containers; Reusable packaging; Self-managed waste; Primary packaging; How parent companies should report data; Check if you need to report nation data; How your data will be used; Examples of how to report data. We’ve added information about multi-material packaging.

31. 24 November 2022

    First published.