Guidance Updated for UK Companies Submitting EPR Packaging Data

Recently, the UK Department for Environment, Food & Rural Affairs (Defra) has issued an updated Guidance¹ on the compilation and submission of packaging data for companies that are affected by EPR for packaging. The guidance, which was originally published in March, was revised on May 19, with the changes primarily focusing on updating "Table 1 Packaging data file structure".

According to Defra, all UK companies that handle and supply (create, import, distribute or sell) packaging and/or packaged goods may be affected by EPR for packaging. To be specific, companies that meet all the four criteria below are required to collect and report packaging data.

• The company is an individual business, subsidiary or group (but not a charity), AND

• The company whose annual turnover has reached or exceeded £1 million, AND

• The company was responsible for more than 25 tons of packaging in 2022, AND

• The company is carrying out any of the packaging activity, i.e., supplying packaged goods to the UK market under the company’s own brand, placing goods into packaging that’s unbranded when it’s supplied, importing products in packaging, owning an online marketplace, hiring or loaning out reusable packaging or/and supplying empty packaging.

Most companies have already started data collection since March 1, 2023.

In addition to reporting the packaging data, companies affected by EPR for packaging may face other obligations² depending on different situations, such as paying a waste manage fee and paying a charge to the environmental regulator. Stakeholders may use the online tool³ provided by UK’s government to figure out if they are affected by the regulation and what to do next. After ensuring the related the obligations, stakeholders shall submit all required packaging data in a single CSV file, and then upload this file to the government’s online EPR for packaging service. Key required packaging data include the following 4 categories.

• Packaging activity—this is how the company supplies the packaging

• Packaging type—e.g., if the packaging is household or non-household

• Packaging class—whether the packaging is primary, secondary, tertiary, etc.

• Packaging material and weight

Please note that companies must use the codes specified in the guidance to represent the required information. E.g., the code “GL” stands for the name “Glass” when submitting the packaging material data. Specific requirements for large/small companies are also provided in the guidance.