Nation-of-sale data submission delayed: What it means for your business

In the continually developing landscape of the UK’s Extended Producer Responsibility (pEPR) for packaging, recent regulatory updates have introduced changes to the nation-of-sale data submission requirements.

Nation-of-sale data should show where in the UK a producer has supplied packaging to an individual or business that is the end-user. This data is intended to determine individual UK nation recycling targets. The term ‘supplied’ in this case refers to the selling, hiring, loaning, or gifting of that packaging.

Originally, businesses were expected to submit 2023 packaging data by December 2024. However, the Department for Environment, Food & Rural Affairs (Defra) has announced a delay, with the first submission now anticipated in July 2025, covering 2024 data.

Who is required to submit nation-of-sale data?

Businesses obligated under pEPR were previously required to submit nation-of-sale data if they engaged in any of the following activities:

• Supplied filled or empty packaging directly to UK end-users.
• Supplied empty packaging to UK businesses that are not obligated or classified as small producers.
• Hired or loaned out reusable packaging.
• Owned an online marketplace where businesses based outside the UK sell their empty packaging and packaged goods to UK users.
• Imported packaged goods into the UK for personal use and discarded the packaging themselves.

Current obligations for producers

The Regulatory Position Statement (RPS) delays the introduction of nation-of-sale reporting, as well as self-managed organisational waste data collection, until the end of 2026. At that point, the Environment Agency (EA) will withdraw the RPS.

It is important to note that the RPS does not change a producer’s legal requirement to report and collect 2024 and 2025 nation-of-sale and self-managed organisational waste data. However, the EA has stated that it will not enforce compliance with these requirements until the RPS expires.

Valpak’s commitment to supporting your compliance

Navigating regulatory changes can be complex. We are dedicated to assisting businesses in understanding and fulfilling their packaging EPR obligations. Our comprehensive services include:

• Data collection and management: We provide tools and expertise to help you accurately collect and manage nation-of-sale data, ensuring compliance with current regulations.
• Regulatory updates: Our Policy team stays up to date with legislative changes, keeping you informed and prepared for upcoming requirements.
• Tailored compliance strategies: We offer customised solutions to meet your specific business needs, minimising the risk of non-compliance.

If you have any questions, please do not hesitate to contact our friendly team of environmental compliance advisors on 03450 682 572.