Packaging data: tell us how you collected it for extended producer responsibility
A guide to documenting how you’ve collected your packaging data, known as your ‘methodology’. Online marketplaces affected by extended producer responsibility (EPR) for packaging must submit a methodology. This is also recommended for all producers as part of their ways of working.
If you are affected by extended producer responsibility (EPR) for packaging, you may need to report data about your packaging. This has to be as accurate as reasonably possible.
You can also submit a document telling the environmental regulators how you gathered and recorded your packaging data. This is known as a ‘methodology’. It helps show that your data accurately represents the variety and amount of packaging you’re responsible for.
Online marketplaces must submit a methodology to the environmental regulator.
All methodologies should be reviewed and updated regularly, so that they reflect changes to suppliers and products.
Who has to tell us
Online marketplaces must submit a methodology. Online marketplaces are businesses that operate a website or app allowing non-UK businesses to sell their goods into the UK.
Online marketplaces should submit their methodology by the deadlines.
Other organisations do not have to submit a methodology. However, having one can provide evidence that:
- you have a clear process in place
- your data is as accurate as reasonably possible
- you have a documented process that is resilient if there is a change to staff or similar disruptions
This is especially useful in the case of compliance audits by the environmental regulators.
What you should tell us
If you’re submitting a methodology, send the information in a Word document to the environmental regulator for your nation.
It should contain:
- a summary of the methodology
- details of your method – for example, sample selection and sizes
- information about the technology used
- any supporting data
- information about future improvement
Retain all relevant information used in developing your methodology in case it needs validation or is audited.
Summary
Your summary should explain what you’ve included and what you’ve left out. For example, you may be excluding your exports from your reporting because they are not obligated.
It should also explain who in your business will be sampling, recording and submitting the data.
Your method
This section should explain how you collect your data and ensure it’s accurate and representative.
Your methodology should cover:
- sampling
- packaging
- suppliers
- customers
- other information
The following lists give examples of what you should include, but they are are not exhaustive.
Sample details must include:
- your sample size
- why you chose certain samples
- how the samples and sample sizes you chose represent your product range
- how the samples represent your suppliers - for example, using more samples for larger suppliers
- details of the sampling procedures - for example, whether product grouping is used and if so, how and where
- how the weights are quality assured
Packaging details must include:
- how you worked out the packaging weight
- your quality assurance process for calculating packaging weight
- how you assigned the packaging type
- how you identified household packaging
- the evidence you used to confirm non-household packaging
- how you define unfilled packaging
- how you collect information for seasonal products
Supplier details can include:
- how you validate weights and other information provided by suppliers
- how you check that scales used by suppliers are accurate, and appropriate for the size and weight of packaging
- what you do when you are unable to obtain data from suppliers
- whether you will try to increase the amount of data you get from your suppliers in the future, and how you’ll achieve this
Customer details can include:
- how you identify business customers who are not legally obligated under EPR for packaging
- how you work out the weight for packaging supplied by organisations that use your online marketplace to supply packaging
Your document can also include:
- how you have taken any seasonal variations into account
- details of the information you’ve collected – for example, how you determined your top products
- questions you ask suppliers and customers
- how you group or categorise your products for sale and how you’ve used this in your data
- how you verify weight data that suppliers have given you
- how you collect nation data
- how you account for any extra packaging that your company uses on top of the original packaging
What technology you use
This should include:
- details of the IT system you use to record data
- how you collect, record, process and report your data
- who is responsible for gathering, uploading and approving the data
- how long you store your data for
- your version control process, if you have one
- how you back up your data
- how your weights are stored – whether updates overwrite them completely or there’s a history
- how you ensure the integrity of the data
Supporting data
There should be supporting information that covers:
- any anomalies you’ve found, such as weights, packaging and seasonal variations
- all background weights gathered as part of the sampling exercise and, if applicable, the average for a given size and type of packaging
- the process for gathering and reporting data, ideally as a flow diagram
- any assumptions made when collecting the data or grouping products
- the type of quality assurance done, including information on who did this and when they did it
- an outline of any information you’d share with the environmental regulator before an audit
Continuous improvement
You must review and update your packaging methodology regularly - at least once per reporting cycle. You should explain how you’ll do this to reflect things like:
- business expansion
- additional brands
- changes to packaging materials
- change in activity and suppliers
- changes to your estimates and assumptions as you gather more data
The document should support or explain how you will achieve a continual improvement in the quality of your data.
This may include frequency of repeat sampling and quality assurance to ensure that the methodology is still appropriate.
Deadlines for submitting your methodology
To comply with the regulations, you need to submit your methodology every 6 months.
If you make any changes to your methodology between reporting periods, you should send the updated version to the regulator. If your methodology has been submitted and is unchanged between reporting periods, you will only need to notify them that nothing has changed.
Reporting periods for 2023
In England, Scotland and Northern Ireland you should submit by:
- 1 October 2023 to report for 1 January to 30 June 2023
- 1 April 2024 to report for 1 July to 31 December 2023
In Wales, you should submit data for 1 July to 31 December 2023 by 1 April 2024.
These deadlines are laid out in the regulations. You should make your best effort to meet them but no enforcement action will be taken about late submission if your methodology is submitted by 31 May 2024.
Reporting periods for 2024
In all 4 nations, you should submit your methodology by:
- 1 October 2024 to report for 1 January to 30 June 2023
- 1 April 2025 to report for 1 July to 31 December 2024
How you should tell us
Email your completed document to the environmental regulator for your nation.
Include your organisation number in the email. You’ll get this number when you create your account to report packaging data.
If you are intending to use another organisation’s methodology, for example a compliance scheme, you must still notify us of this intention and this EPR methodology must have already been submitted to the regulator.
Environmental regulators
For England, the environmental regulator is the Environment Agency.
For Wales, the environmental regulator is Natural Resources Wales.
For Northern Ireland, the environmental regulator is the Northern Ireland Environment Agency.
Email: packaging@daera-ni.gov.uk
For Scotland, the environmental regulator is the Scottish Environment Protection Agency.
What happens after you’ve told us
If there’s a problem, the environmental regulator will contact you.
If the regulator for your nation finds a problem, you’ll have to revise your methodology and submit it again. You may also need to update and re-submit your packaging data. This is so that all your data is as accurate as possible.
Updates to this page
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Clarifying information about deadlines and updating email contact for EA.
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Adding a line to section 'Who has to tell us' to clarify when online marketplaces should submit their methodology - as soon as possible, but it must be before submitting their data.
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First published.