Every year, thousands of UK businesses submit packaging data under packaging EPR. And every year, a significant number get it wrong, not because they are not trying, but because the data requirements are genuinely complex and the guidance is not always easy to translate into practice.
At Valpak, we work with businesses across every sector to collect, review and submit packaging data each reporting cycle. This guide covers what you actually need to collect, how to classify it correctly, and where businesses most commonly trip up. If you are new to EPR data reporting, or you have done it before and want to make sure you are getting it right, this is the place to start.
The short answer: you need to report the weight of all packaging you supply in the UK, broken down by material, packaging type, and end-of-life waste stream.
This is the foundation of EPR data reporting. For every packaging activity your business carries out, you need to capture three core data points:
All weights are reported in kilograms. The level of detail required is greater than under the old Packaging Waste Regulations, which is why many businesses find data collection more time-consuming than they expected the first time around.
The short answer: report the weight of each material type separately. For packaging made from multiple materials, classification depends on whether the components can be manually separated.
The main packaging materials you will need to report are:
This is where classification gets more nuanced, and where we see a lot of errors in practice.
If your packaging is made from two or more materials that are bonded or laminated together, it is composite packaging. You report it as a single component classified by the primary material, the one that makes up the greatest weight. A drinks carton made from layers of cardboard, plastic and aluminium would be reported as cardboard if that is the heaviest component.
If your packaging is made from separate components, it is multi-material packaging. A glass jar with a metal lid is a common example. Each component is reported separately, with its own material type and weight.
Fibre composite packaging has its own classification: the main material is paperboard or paper fibres, laminated with plastic, and possibly other layers. It has a separate reporting category from standard paper or cardboard. If the total component weight is under 5% plastic you should report it as paper.
The short answer: packaging class determines whether EPR waste management fees apply. Primary (household only) and ecommerce packaging incur fees. Secondary and tertiary packaging do not, but still require reporting and PRN coverage.
Primary packaging
The packaging that directly contains a single sales unit. A bottle, a wrapper, a tub. The packaging around that product is primary packaging. It must be reported and if it is a household product then EPR fees apply.
Secondary packaging
Packaging that groups together several units for sale or transport. A cardboard tray holding multiple multipacks is secondary packaging. Secondary packaging does not incur EPR waste management fees because it does not typically reach household bins. You still need to report it and purchase PRNs to meet your recycling obligation.
Tertiary packaging
Packaging used to bundle and protect goods during transport through the supply chain. Pallets, corrugated outers, stretch wrap and plastic strapping are all common examples. As with secondary packaging, no EPR fees apply but reporting and PRN obligations remain. Shipping containers used in road, rail, sea or air freight are excluded entirely.
Ecommerce and shipment packaging
Any additional packaging added when goods are sold directly to a customer or at a collection point. If you sell online and add protective packaging around your product before dispatch, that outer packaging counts as ecommerce or shipment packaging. This includes retail carrier bags. It ends up in household bins and is subject to EPR reporting and fees.
The short answer: if you cannot prove packaging went directly to a business end user, treat it as household. The default is always household, and the evidential bar for non-household is high.
This distinction matters financially. EPR waste management fees only apply to household packaging. Getting this classification wrong, either by over-reporting as household or by claiming non-household without adequate evidence, has direct cost implications.
Household packaging includes primary and shipment packaging supplied to consumers, and any packaging where you cannot demonstrate it went directly to a business or public organisation as the final user.
Non-household packaging can only be claimed in specific circumstances:
You must retain evidence for all non-household claims for seven years. The types of evidence that may be acceptable include contracts specifying packaging is not passed on, sales records showing packaging is removed before goods are transferred, signed customer declarations, or product information confirming the goods are for business use only. A single document is often not sufficient. A combination of evidence is typically stronger.
One practical note from working with businesses on their data: where packaging is supplied to both consumers and businesses, it must be reported as household unless you can prove, for each specific supply, that it met the non-household conditions. The default is always household.
The short answer: nation of sale data requires you to declare which UK nation you have supplied packaging into. Data collection starts 1 January 2026, with reporting due 1 April 2027. It is about where you supplied the packaging, not where it becomes waste.
Nation of sale reporting is one of the most misunderstood elements of the whole EPR system. Many businesses assume it means tracking where their packaging ends up as waste across England, Scotland, Wales and Northern Ireland. That is not what it requires.
What you are reporting is where in the UK you have directly supplied packaging to an end user, whether a consumer or a business. For packaging moving through the middle of supply chains, such as secondary and tertiary packaging supplied to a retailer, it is the retailer or end customer who reports the nation data, not the upstream supplier.
Following a Regulatory Position Statement, nation of sale data reporting was delayed. Data collection now begins 1 January 2026, with the first enforced reporting deadline of 1 April 2027. If you have been concerned about this obligation, you have time to prepare, but it is worth understanding the requirement now rather than leaving it until the deadline approaches.
The short answer: in general, large producers submit every six months, while small producers submit annually. The reporting periods and deadlines differ, so it is worth confirming which category you fall into. Reporting for nation of sale and carrier bags takes place annually.
Large producers (turnover over £2 million and over 50 tonnes of packaging per year)
You must report twice a year, covering both household and non-household packaging on the same submission. EPR waste management fees apply in addition to your PRN obligations.
Small producers (turnover between £1 million and £2 million and 25-50 tonnes, or turnover over £2 million but 25-50 tonnes)
You submit one annual report. EPR waste management fees do not apply to small producers, but the reporting obligation does. Your data contributes to the national picture of packaging volumes and helps set recycling targets.
All producers must register through the government’s Report Packaging Data (RPD) portal. Your account must be approved by the environmental regulator before you can submit data, which can take up to 28 days, so it is worth registering early.
Please note that for Valpak members, this submission is completed through the Valpak Members Area.
The short answer: the most common errors are misclassifying packaging types, defaulting to household when non-household evidence exists (or claiming non-household without adequate evidence), and underestimating the weight of composite or multi-material packaging.
This is where Valpak’s experience as a compliance scheme becomes genuinely useful. We review packaging data from businesses across every sector, every reporting cycle. Here are the mistakes we see most often:
Businesses sometimes report outer cartons or retail display packaging as primary packaging. The distinction matters because primary packaging attracts EPR fees and secondary does not. Getting this wrong in either direction creates either an overpayment or a compliance gap.
Claiming non-household status is legitimate when the conditions are met and the evidence is in place. But we regularly see businesses applying it based on a general assumption that their customers are businesses, without the contracts, declarations or records that would support the claim under audit. If the evidence is not there, the packaging should be reported as household.
Businesses dealing with composite materials, such as laminated packaging or drinks cartons, sometimes report only the weight of the primary layer rather than the full component weight. The full weight of the composite item should be reported under the primary material.
Businesses that have added online sales channels sometimes continue to report packaging data based on their original product lines only, forgetting that the protective and outer packaging added for dispatch counts as ecommerce packaging and needs to be reported separately.
Packaging data needs to be accurate, and accuracy takes time. Businesses that start pulling data together in the weeks before a deadline are more likely to make classification errors, miss categories, or produce estimates rather than actual weights. Building a data collection process throughout the reporting period produces significantly better results.
Valpak is one of the UK’s leading compliance schemes for packaging EPR. We help businesses of all sizes manage their data collection, classify packaging correctly, and submit accurate reports on time.
Working with Valpak means:
Not sure whether EPR applies to your business, or whether you are a small or large producer? Our free obligation checker and pEPR Cost Calculator are both available on the Valpak website.
If you would like to talk through your data collection process or find out how Valpak can support your compliance, get in touch with our team here.
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You need to report the weight in kilograms of all packaging you supply in the UK, broken down by material type (such as plastic, glass, cardboard or aluminium), packaging class (primary, secondary, tertiary or ecommerce), and anticipated end-of-life waste stream (such as household, street bin or drinks container).
Composite packaging, made from materials that cannot be manually separated, is reported as a single component classified by its primary material, the one with the greatest weight. Multi-material packaging, where components can be separated by hand, is reported with each component listed separately by material type and weight.
Household packaging is any packaging likely to end up in a household or public bin. EPR waste management fees apply to household packaging. Non-household packaging is only packaging you can prove was supplied directly to a business or public organisation as the final user, or that you imported and discarded yourself. The default is always household, and non-household claims require documentary evidence retained for seven years.
Large producers, defined as businesses with a turnover of over £2 million that supply more than 50 tonnes of packaging per year, must submit packaging data twice a year. Small producers submit once annually.
If you submit through Valpak, your data is submitted via the Valpak Members Area. If you submit independently, all data must be submitted through the government’s Report Packaging Data portal.
Yes. Any protective or outer packaging added when goods are sold online or by mail order and sent directly to a customer or collection point counts as ecommerce or shipment packaging. It ends up in household bins and is subject to EPR reporting and waste management fees.
Nation of sale data collection starts 1 January 2026, with the first reporting deadline of 1 April 2027. It requires producers to declare which UK nation they have supplied packaging into, not where the packaging ultimately becomes waste.
Submitting inaccurate data is a regulatory breach under EPR. It can result in incorrect fees, resubmission costs, and potential enforcement action. Businesses that identify errors and correct them proactively are in a much stronger position than those whose inaccuracies are identified by regulators. Working with a compliance scheme such as Valpak includes a data review before submission to reduce this risk.
No. You can register and submit data directly through the government’s Report Packaging Data portal. However, working with a compliance scheme reduces your government registration fee, gives you access to expert guidance on data classification and packaging type queries, and includes PRN procurement support. For many businesses, the cost of the scheme is offset by the fee reduction and the time saved on data management.