Recording and reporting packaging waste: reprocessors and exporters
How to record and report data under extended producer responsibility (EPR) for packaging requirements.
When to submit reports
Operators with accredited materials
If you are accredited to reprocess or export a material, you must submit monthly reports to your regulator for each accreditation you hold.
Monthly reports for accredited operators are due by the 21st day of each month (for the previous calendar month) and started in February 2026.
You must also submit an annual report by 28 February in the year following the accreditation year.
Regulatory position statements for accredited materials reporting
The Environment Agency has issued a regulatory position statement (RPS) about monthly reporting for accredited operators.
Natural Resources Wales has a regulatory statement to apply the same approach in Wales. The statement has been communicated directly to operators in Wales. Contact packaging@naturalresourceswales.gov.uk with any questions.
Northern Ireland Environment Agency has an RPS to apply the same approach in Northern Ireland. The RPS has been directly communicated to operators in Northern Ireland. Contact repandexp@daera-ni.gov.uk with any questions.
Scottish Environment Protection Agency (SEPA) does not have an RPS in place. Operators can submit the information required in the monthly report to SEPA at producer.responsibility@sepa.org.uk. This information has been communicated directly to operators regulated by SEPA. Contact SEPA if this way of submitting the information is a challenge for you.
Operators with materials that are registered only
If you are registered but not accredited to reprocess or export a material, you must submit quarterly reports for that material to your regulator. Quarters are based on a calendar year.
Quarterly reports are due before the 21st day of each month following the end of the quarter, starting in April 2026. Submit your reports before:
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21 April
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21 July
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21 October
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21 January
You must also submit an annual report before 21 March in the year following the year to which the report relates. This is a consolidation of the past 12 months’ data.
If you have not received or exported packaging waste for reprocessing during the quarter you must submit a nil return.
How to record and report data
Enter data in summary logs
Operators with accredited materials must record data about packaging waste activity in summary logs and upload the summary logs to the ‘Record reprocessed or exported packaging waste’ service.
For operators with registered-only materials, completing summary logs will support you to record the data you are required to report.
The data you upload in your summary logs will be used to:
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generate your monthly or quarterly reports
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calculate the ‘waste balance’ from which you can issue packaging recycling notes (PRNs) and packaging export recycling notes (PERNs) if you’re accredited
Read more about summary logs.
Submit reports using the ‘Record reprocessed or exported packaging waste’ service
To report data to regulators, you must use the ‘Record reprocessed or exported packaging waste’ service to create and submit your reports.
The service will pull together the relevant data from your summary logs and PRN or PERN records.
You will then need to add some remaining data manually. You will need to keep your own records so you can enter this data into your monthly and quarterly reports.
Your monthly or quarterly reports can only be verified and submitted by an approved person.
What data to report
For each registration or accreditation you hold, you need to report certain data to the relevant regulator.
You need to provide this information for each material you are registered or accredited for.
For detailed definitions of the data you need to include in summary logs and how to calculate the figures you need, see the summary logs supplementary guidance and find the data point in the relevant template.
Data reprocessors must report
In monthly reports (reprocessors with accredited materials) and quarterly reports (reprocessors with registered-only materials), you must include the following:
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the tonnage of packaging waste you received for recycling during the reporting period
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details of the suppliers from whom you have received packaging waste during the period
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the tonnage of packaging waste you have recycled in the period
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the tonnage of packaging waste you received during the period but have not recycled (‘unrecycled packaging waste’)
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the tonnage of unrecycled packaging waste you have ‘sent on’ during the period
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details of the other reprocessors, exporters or facilities to which you have ‘sent on’ unrecycled waste during the period
In monthly reports, accredited reprocessors must also include:
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the tonnage of PRNs issued under this accreditation during the reporting period
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the average price per tonne that you received for PRNs sold under this accreditation during the reporting period
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the total revenue you received (excluding VAT) for the PRNs sold under this accreditation during the reporting period
In annual reports, accredited reprocessors must also include details of how you have used the revenue from PRNs, compared to how you indicated you would use it in the business plan you supplied in your accreditation application. You must explain any significant differences.
All of the data above is captured in your summary logs, except for:
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the tonnage of packaging waste that you recycle each month
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how much of the packaging waste you received but did not recycle each month
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the revenue you receive for the sale of PRNs and how you have used it in each year
You will have to enter this data manually when you submit your reports.
Data exporters must report
In monthly reports (exporters with accredited materials) and quarterly reports (exporters with registered-only materials), you must include the following:
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the tonnage of packaging waste you received for export for recycling during the reporting period
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details of the suppliers from whom you have received packaging waste during the period
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the tonnage of packaging waste you have exported for recycling during the period and the overseas reprocessing sites to which it was exported
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details of any waste stopped during export or refused by the overseas reprocessing site, or repatriated during the period
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the tonnage of packaging waste you received for export for recycling during the period but have not exported (‘unexported packaging waste’)
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the tonnage of unexported packaging waste you have ‘sent on’ during the period
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details of the other reprocessors, exporters or facilities to which you have ‘sent on’ unrecycled waste during the period
In monthly reports, accredited exporters must also include:
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the tonnage of PERNs issued under this accreditation during the reporting period
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the average price per tonne that you received for the PERNs sold under this accreditation during the reporting period
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the total revenue you received (excluding VAT) for the PERNs sold under this accreditation during the reporting period
In your annual reports, accredited exporters must also include details of how you have used the revenue from PERNs compared to how you indicated you would use it in the business plan you supplied in your accreditation application. You must explain any significant differences.
All of the above data is captured in your summary logs, except for:
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the tonnage of packaging waste that you have received for export but have not exported during the period
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the revenue you receive for the sale of PERNs and how you have used it
You will have to enter this data manually when you submit your reports.
Reporting the recyclable proportion
When reporting tonnages in your monthly, quarterly and annual reports, you must only report the weight of the ‘recyclable proportion’ of the total packaging waste material.
Your sampling and inspection plan must set out how you will calculate the recyclable proportion of the packaging waste material you receive.
Read more about sampling and inspection plans (SIPs).
What data and supporting documentation to record
You must keep supporting documentation for 7 years and make it available for inspection.
All registered and accredited reprocessors and exporters
You must keep records of:
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details of the permits, licences and authorisations that you hold as a reprocessor or exporter
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waste transfer notes and receipts
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the sampling and inspection you carry out of the packaging waste that you receive for recycling or export
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records of the weight of material recycled and when it was recycled - either at a UK or overseas reprocessing site
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packaging waste that you have received but not recycled or exported
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unrecycled or unexported waste that you’ve sent on to other facilities in the UK
All reprocessors
All reprocessors must also keep records of the outputs from your recycling process.
If you’re accredited, you must also keep financial records of the revenue that you receive from the PRNs or PERNs you issue under each accreditation you hold, and of how you use that income.
All exporters
All exporters must also keep the following records:
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export paperwork such as customs declarations and Annex VII forms
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the overseas order or purchase agreement
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whether the shipment has cleared customs in the receiving country
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its receipt by the overseas site you have named
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that the packaging material has been accepted and recycled by an appropriately permitted overseas site
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the final destination site
Accredited exporters
Accredited exporters must also record:
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documents and records to evidence that the recycling operations at the overseas sites to which you export packaging waste for recycling take place under conditions that are broadly equivalent to requirements applicable to reprocessing sites in the United Kingdom
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financial records of the revenue that you receive from the PERNs you issue under each accreditation you hold, and of how you use that income
You must also record documents and records to demonstrate a full audit trail for each exported load, from export to proof of receipt at the final overseas site. These may include, but are not limited to:
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a completed and signed annex VII form
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other waste movement or shipment documentation, such as a bill of lading
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time and date stamped photographs at the overseas site
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weighbridge tickets from the overseas site
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customs documents
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correspondence about invoices or specification of material received
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proof of payment such as bank statements or financial documents
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other correspondence from the overseas site
This list is not exhaustive, and regulators would expect to see a combination of evidence to demonstrate proof of receipt. They will consider other evidence presented to them on a case-by-case basis.