Extended Producer Responsibility

pEPR Recyclability Assessment Deadline Extended

July 2, 2025 by Susie

The Environment Agency has just published RPS 350, providing regulatory relief for packaging producers who haven’t completed their recyclability assessment obligations.

RPS 350: RAM Assessment Relief Available Until April 2026

RPS 350 is a Regulatory Position Statement that says the Environment Agency will not normally take enforcement action against producers who are unable to meet the original 1 October 2025 deadline for recyclability assessments covering household packaging supplied in January-June 2025 (H1), provided specific conditions are met.

All four UK nations have issued equivalent regulatory relief: England (RPS 350), Wales (Regulatory Decision), Scotland (SEPA statement), and Northern Ireland (NIEA statement). The legal obligations remain unchanged across all nations — this provides enforcement relief only. Non-household packaging obligations are unaffected.

In our view, this pragmatic response acknowledges the practical difficulties many producers have faced, including late publication of guidance, evolving requirements, and communication challenges around the new assessment methodology.

Your Compliance Options

Producers can still meet the original 1 October 2025 deadline for H1 assessments, or they can use RPS 350 relief with one of two conditions:

Condition 1: Complete H2 2025 (July-December) recyclability assessment obligations by 1 April 2026.

Condition 2: Complete both H1 and H2 2025 recyclability assessment obligations by 1 April 2026.

The choice between conditions 1 and 2 is simply whether you do the additional H1 assessment work. Both must meet the conditions outlined below.

Conditions for Using RPS 350

To benefit from enforcement relief, you must:

Keep records of H1 recyclability assessments (even if not submitted)
Read PackUK’s statement on disposal fee liability
Check back periodically as the Environment Agency may withdraw or amend RPS 350 before 31 January 2027
Subscribe to GOV.UK email alerts for RPS 350 updates

Financial Implications to Consider

Before choosing RPS 350, you should review PackUK’s fee impact statement as their extrapolation method could cost you more than completing your own H1 assessments.

The Key Issue: Fee Modulation

From 2026-2027, disposal fees will be “modulated” (adjusted) based on your RAM ratings. The modulated fee is calculated by multiplying the EPR Base Fees for 2025 by the modulation factor:

Red packaging = higher fees (confirmed 1.2x base fee in 2026; indicative 1.6x in 2027, 2.0x in 2028 subject to policy confirmation)
Green packaging = discounted fees (discount varies based on total Red packaging revenue redistributed)
Amber packaging = standard base fees (no modulation)

What Happens If You Use RPS 350

If you don’t submit H1 2025 assessments and rely on RPS 350, PackUK will:

Take your H2 2025 RAM ratings (July-December 2025)
Extrapolate them back to cover your H1 2025 packaging tonnages
Apply the same proportions of Red/Amber/Green ratings to your whole year

What to Look For

The extrapolation method creates risk when:

Your H2 packaging was worse (more Red ratings) than your H1 packaging
Your product mix changed significantly between H1 and H2

Example: If your H2 2025 data shows 30% Red ratings, PackUK will assume your H1 2025 also had 30% Red – even if your H1 packaging was actually better and would have scored fewer Red ratings.

However, if you improved your packaging during 2025, the extrapolation would actually benefit you as your better H2 ratings would be applied to your whole year.

Strategic Implications

This regulatory relief indicates that authorities expect full compliance going forward, but recognise the implementation challenges producers have faced. The Environment Agency’s approach is pragmatic rather than punitive during this transition period.

However, this is temporary relief with a clear end date. RPS 350 will be withdrawn on 31 January 2027, though the Environment Agency may amend or withdraw it sooner if necessary. The underlying legal obligations remain unchanged.

The extension provides an opportunity to:

Implement robust data collection systems
Ensure accurate packaging categorisation
Develop reliable processes for ongoing compliance
Assess the financial implications of different compliance strategies

Looking Ahead

This regulatory position statement signals that full compliance will be expected going forward. The extension is a one-time opportunity to establish proper compliance infrastructure, not an indication that standards will be relaxed.

For businesses still developing their pEPR systems, RPS 350 offers breathing room to invest in comprehensive compliance solutions without immediate enforcement pressure. The EPR landscape will continue to evolve, and having robust systems in place is essential for managing ongoing regulatory requirements effectively.

Whether you’re taking advantage of this extended deadline or already meeting your compliance obligations, the complexity of EPR requirements makes having the right tools and processes crucial for long-term success.

PackTotal runs quietly on your servers, turning raw packaging data into regulator-ready EPR reports. Nothing confidential leaves the building. If you’d like a no-obligation demo, drop us a note and we’ll book a time that suits.

EPR Base Fees 2025 – How Accurate Data is Key to Minimizing Costs

June 30, 2025 by Susie

Understanding the Financial Impact of EPR Fees

By now, most businesses in the packaging sector are aware of the UK’s Extended Producer Responsibility (EPR) scheme, but with the recent release of illustrative base fees, the actual costs are starting to hit home. If you’ve been putting off preparation, the time to act is now—because when the EPR fees go live in 2025, your packaging decisions could either protect your bottom line or lead to unexpected financial hits.

The EPR scheme is intended to shift the financial burden of packaging waste management from local councils to the businesses that produce or use packaging. For many companies, this represents a significant change in how they track, manage, and report their packaging data. In fact, getting the details right is now more important than ever because any errors in classification or reporting could lead to overpayment—and potentially hefty fines if you fail to comply with the new regulations.

But there’s good news: by acting now and leveraging the right tools, your business can avoid overpaying and ensure smooth compliance with the upcoming regulations. This article will break down the EPR fee structure, explain why accurate data reporting is key, and show how PackTotal can help you to easily and accurately collate and calculate your EPR obligations.

The Numbers That Matter: Understanding the EPR Fees

The UK government has published the base fees that will apply under the EPR scheme for the year 2025 to 2026. These fees are linked to the type of packaging material you place on the market or dispose of. From 2026, the environmental impact of those materials will influence the amount you pay. The idea is to encourage businesses to shift towards more sustainable packaging solutions—so the less environmentally friendly the material, the higher the cost.

Here’s a breakdown of the base fees for 2025/26 for each packaging material in £ per tonne:

Material	Rate
Aluminium	£266
Fibre-based composites	£461
Glass	£192
Paper or board	£196
Plastic	£423
Steel	£259
Wood	£280
Other	£259

EPR Base Fees released by DEFRA on 30th June 2025

Why Accurate Data Is Critical to Minimizing EPR Costs

The EPR fees aren’t just a flat tax; they’re tied to your ability to classify and report your packaging data correctly. Misclassification can result in higher costs. For instance, household packaging waste typically incurs higher full net cost fees, while non-household waste is subject to PRNs (Packaging Recovery Notes), which are likely to be cheaper.

If your business can’t provide clear evidence that your packaging waste falls under the non-household category, you may face unnecessary costs that directly impact your bottom line. Moreover, industry experts warn that these extra fees might be passed on to consumers. A recent report from The British Home Enhancement Trade Association indicated that the packaging tax could lead to price increases on common household items like food, beverages, and cleaning products. Some analysts suggest UK households could see an increase of up to £60 per year in their spending due to these additional packaging costs.

It’s clear that data collection and classification accuracy will be essential for businesses looking to avoid overpaying. But this isn’t something you can easily manage with a spreadsheet—especially if you’re dealing with large volumes of packaging data across multiple departments.

PackTotal: The Solution for EPR Compliance and Cost Control

So, how can you ensure your business is prepared to meet the new EPR requirements and avoid overpaying?

This is where PackTotal’s packaging management system comes in. Our software is designed specifically to help businesses track, manage, and classify their packaging data with complete accuracy.

PackTotal simplifies data collection by enabling each department to input and manage its own data, ensuring responsibility is shared across your team. To further enhance accuracy, PackTotal can automatically import data from your existing management systems, significantly reducing the risk of human error associated with manual data entry. This approach minimizes the chances of data collation errors, ensuring your reporting is both accurate and fully compliant.

With EPR fees evolving and new regulations being introduced regularly, PackTotal ensures that your calculations are always up-to-date and compliant—automatically. This eliminates the need for manual tracking of every regulatory change, a time-consuming and error-prone process when relying on spreadsheets.

Beyond compliance, PackTotal provides valuable insights into your packaging data, allowing you to make informed decisions about materials. If you’re using materials that are costly under the EPR scheme, PackTotal can help you identify opportunities to switch to more sustainable, cost-effective alternatives.

Preparing for Future Changes: The Evolution of EPR

While the EPR fees come into effect in 2025, the fee structure is set to evolve further. The introduction of modulated fees in 2026 will mean that packaging materials with a higher environmental impact will attract even higher costs, while more easily recyclable materials will come with lower fees.

This shift is designed to encourage businesses to adopt greener packaging practices. Companies that fail to adapt could likely face even steeper costs in the coming years. By preparing now, businesses can avoid future penalties and position themselves as leaders in sustainable packaging.

PackTotal can help you navigate these changes by providing detailed reporting on the materials you use and how they impact your costs. With clear data, you can make strategic decisions to shift towards more sustainable materials that reduce your environmental impact and save on EPR fees in the long term.

How Can Your Business Stay Ahead of EPR?

While the EPR scheme presents challenges, it also offers opportunities. Companies that take proactive steps to improve data accuracy, streamline compliance processes, and shift to more sustainable packaging will be better positioned to manage costs and avoid penalties.

With PackTotal, you can take control of your packaging data and ensure that your business is ready to meet the evolving EPR requirements. From accurate data tracking to real-time regulatory updates, PackTotal simplifies compliance and helps you avoid costly mistakes. More importantly, it empowers you to make informed decisions about your packaging materials, reducing costs while improving sustainability.

Want to learn more about how PackTotal can help your business stay compliant and minimize EPR costs? Contact us to discuss how we can help or to schedule a demo.

EPR Tertiary Packaging Data Collection Options

June 13, 2025 by Susie

How to Record Tertiary Packaging for UK EPR: Your Options Explained

If your business supplies goods using pallets, shrink wrap, trays, or other outer packaging, then you’re dealing with what’s known as tertiary packaging — and under the UK’s Extended Producer Responsibility (EPR) regulations, you’ll need to report it.

But how exactly should you record it?

The good news is that the regulations offer flexibility. You don’t have to measure every piece of tape. What’s required is a method that’s accurate as far as reasonably possible, documented, and repeatable — one that reflects the packaging you actually use in practice.

There are four main approaches, all of which are supported by PackTotal. Each has its place depending on how your warehouse operates, and we’ve outlined them below to help you choose the one that fits best.

1. Order-Based Tracking

How it works: You record packaging based on the type of order. For example, a large wholesale shipment might always use a pallet and shrink wrap, while a smaller parcel goes into a box. This approach relies on predefined packing rules linked to order size or weight.

Ideal for: Warehouses with standardised packing procedures or automated picking systems.

Why it’s compliant: Regulators accept this method as long as it’s clearly documented and applied consistently. You’ll need to keep a record of the rules and show that they reflect your actual processes.

In PackTotal: You can configure rule-based logic that automatically assigns packaging based on order characteristics.

2. Stocktake / Usage Tracking

How it works: Instead of estimating what each order uses, you calculate your packaging use by tracking stock levels over time:

Opening stock + purchases – closing stock = packaging consumed

Ideal for: Businesses with manual packing processes, multiple packing types, or limited systems integration.

Why it’s compliant: This method is considered direct measurement. As long as stock records are accurate and verifiable, it provides a clear audit trail of actual packaging use.

In PackTotal: You can enter weekly or monthly consumption figures, and PackTotal will calculate the associated packaging weights automatically.

3. Product or BOM-Based Tracking

How it works: You assign standard packaging configurations to each product or product group (e.g. “Product X always ships on 1 pallet with 20 metres of shrink wrap”). These assumptions are based on your Bill of Materials (BOM) or internal specs.

Ideal for: Manufacturers and suppliers with consistent, repeatable packing specifications.

Why it’s compliant: As long as the BOM reflects real-world practice — and is reviewed periodically — this approach is accepted under the EPR regulations. You’ll need to document your assumptions.

In PackTotal: Packaging can be defined per product or component, and reused across multiple SKUs to avoid duplication.

4. Integrated Tracking per Sale

How it works: This is the most precise method. Your system records the actual packaging used for each order, typically via an integrated ERP, WMS, or despatch system. For example, the system might record: “Order 1234 used 1 pallet, 2 corner protectors, and 1.5kg stretch film.”

Ideal for: Businesses with advanced systems and real-time tracking capabilities.

Why it’s compliant: This is the most precise approach available, and it’s encouraged by regulators where feasible. It provides the clearest evidence that your reports reflect actual packaging usage.

In PackTotal: You can import or enter this data directly or use API links to external systems if available.

Which Method Should I Use?

There’s no one-size-fits-all answer. The best method for you depends on:

How consistent your packing processes are
What data you already collect
What systems you use

Each method is compliant, as long as it’s applied consistently and supported by records.

And if your processes change? No problem. You can switch methods as needed — just keep a note of what you changed and when.

PackTotal Makes It Easy

Whichever approach you use, PackTotal is built to support it. From simple rule-based setups to detailed per-despatch tracking, the system offers flexible options to match your operational reality. You can:

Apply allocation rules per order
Record consumption figures from stocktakes
Link packaging to products and BOMs
Import packaging records per despatch

It’s all backed by clear audit trails and reporting tools designed with EPR in mind.

Many businesses start with one method and refine it over time — PackTotal makes that evolution smooth. You can begin simply and build toward more detailed tracking without losing data or retraining your team. We’ve designed the system to help you stay compliant and work efficiently.

If you’re planning to implement or upgrade your packaging data processes using PackTotal, we’ll work with you to make sure the method you choose fits your setup and meets regulatory expectations.

Interested in seeing how PackTotal can help?
Contact our team — we’ll be happy to show you what’s possible.

What the New Recyclability Assessment Methodology Means for Producers

February 16, 2025 by Susie

The long-awaited details of the Recyclability Assessment Methodology (RAM) were finally released by DEFRA on December 23rd, 2024. With implementation just days away, producers now have clarity on how they’ll need to assess and report the recyclability of their household packaging from January 2025. The first EPR return which includes RAM assessments is due by the 1st October 2025

What’s Been Announced?

The RAM framework introduces a comprehensive five-stage assessment process that will determine whether packaging components receive a red, amber, or green rating. These ratings will directly influence the modulated fees producers pay under EPR from 2025 onwards, with more recyclable packaging attracting lower fees, making this a critical financial consideration for producers.

One of the most significant aspects of the methodology is its approach to component assessment. Packaging elements that cannot be easily separated by hand must be assessed together as a single unit. For instance, a plastic bottle with a firmly adhered label would be evaluated as one component, while a bottle with an easily removable sleeve would have each part assessed separately.

The Five Stages of Assessment

The assessment process follows a logical progression through five key stages:

Classification: Packaging must be categorized into one of eight material types: paper and board, fibre-based composites, plastic (both flexibles and rigids), steel, aluminium, glass, wood, or other materials. For combined units, classification is based on the predominant material by weight.
Collection: Assessment of whether the packaging is widely collected by local authorities (75% or more), has limited collection (50-75%), or requires take-back schemes.
Sortation: Evaluation of whether the packaging can be effectively sorted in materials facilities, considering factors like size, shape, and material detection.
Reprocessing: Assessment of whether the packaging can be effectively reprocessed using current UK infrastructure, taking into account contamination and material composition.
Application: Consideration of whether the recyclate produced can be effectively used in new products.

Immediate Implications for Producers

The timing of this announcement, just days before implementation, presents some immediate challenges for producers. However, the methodology itself provides clear criteria for assessment, which should help organizations prepare their packaging portfolios for evaluation.

Key points producers need to consider:

Documentation requirements are substantial, with evidence needing to be maintained for 7 years
The assessment of inseparable components as single units will require careful analysis of existing packaging designs
Take-back schemes may offer a route to improved ratings for packaging not widely collected at kerbside
Technical specifications for each material type are detailed and specific
While some materials like glass (89% collection rate) and metal cans (100% collection rate) have clear assessment paths, others like flexible plastics (14% collection rate) will require careful consideration of take-back schemes or alternative solutions.

Looking Ahead

While the immediate focus will be on completing initial assessments, the longer-term implications of RAM are significant. The methodology creates clear incentives for improved packaging design, particularly around component separability and material selection.

The framework will be reviewed and updated annually by the Technical Advisory Committee (TAC), allowing it to evolve with technological advances and changes in recycling infrastructure. These reviews will ensure the methodology stays current with market conditions and innovations in packaging design and recycling capabilities. This means producers should view their initial RAM assessments as the beginning of an ongoing process rather than a one-time exercise.

The regular review cycle also presents opportunities for producers to influence future developments through early adoption of more recyclable packaging solutions. Companies that take a proactive approach to improving their packaging recyclability now may find themselves better positioned as the methodology evolves.

Practical Steps for Compliance

To prepare for RAM implementation, producers should:

Review their packaging portfolio to identify which components must be assessed together
Begin documenting separation tests and decisions
Gather technical specifications for all packaging materials
Set up systems to track and maintain RAM assessment evidence
Consider how RAM ratings might influence future packaging design decisions
Identify any packaging with ‘automatic red’ classifications (e.g., those containing SVHC substances or integrated electrical components)
For composite materials, calculate and document material percentages by weight

The Broader Impact

The introduction of RAM represents a significant step toward more sustainable packaging design in the UK. By directly linking recyclability to EPR fees, it creates a clear financial incentive for improvement. This could accelerate the trend toward more easily recyclable packaging and potentially drive innovation in packaging design and materials.

How PackTotal Can Help

For producers grappling with these new requirements, PackTotal’s packaging management system provides the essential foundation for RAM compliance. The system already handles the complex relationships between packaging components, accurately tracking which elements must be assessed together – a critical requirement for RAM.

Our system’s ability to track component relationships is particularly valuable for producers with complex packaging portfolios, where manual tracking of separable versus inseparable components would be time-consuming and error-prone. The robust database structure manages your complete packaging hierarchy while maintaining the required documentation trail for regulatory evidence – crucial for the seven-year record retention requirement.

We’re actively developing comprehensive RAM assessment capabilities to integrate seamlessly with these existing features. With modulated fees directly linked to RAM ratings, having a structured system for managing your packaging data and relationships isn’t just about compliance – it’s about protecting your bottom line.

Final Thoughts

While the late December release of the RAM details has created some pressure for producers, the methodology itself appears well-thought-out and aligned with broader EPR objectives. The focus on component separability and clear assessment criteria provides a practical framework for improving packaging recyclability.

For more detailed information about the RAM requirements and how to prepare for compliance, producers should refer to the guidance published on the UK government website.

Preparing Your Business for RAM

The key now is to establish robust systems for managing your packaging data and component relationships. Organizations that take a systematic approach to RAM assessment and documentation will be better positioned to optimize their ratings and manage their EPR costs effectively.

PackTotal provides the foundational data management capabilities you need, accurately tracking packaging components and their relationships while maintaining comprehensive documentation trails. As RAM requirements evolve, we’re developing additional features to support your compliance journey.

Want to ensure your business is ready for RAM? Contact us to discuss how PackTotal can help you prepare for these new requirements or to schedule a demo.

How PackTotal Calculates Extended Producer Responsibility Data

April 12, 2024 by Susie

Companies in the UK are now obliged to report on and pay modulated fees for product packaging they handle. The amount each company must pay will be initially calculated according to the type of material used and who is responsible for each item of packaging placed on the market.

PackTotal software is designed to simplify the complex task of collating, categorising and analysing packaging data and ensuring accuracy.

On-Premises Solution

Our packaging data management software solution keeps your proprietary information secure by storing it in-house on your company’s servers.
The easy-to-use dashboard gives you a centralised view of your packaging data, ensuring everyone in your organisation can easily access all the tools necessary to manage your reporting.

Advanced Reporting

Collecting, formatting, and submitting compliance data can be complex and time-consuming. Calculating the volumes of each material handled is a mammoth task, and it is even more complicated to split it into the many categories and subcategories that must be reported to HMRC.

PackTotal automatically calculates and categorises the data into each packaging activity, class and material that must be reported.

EPR is based on the principle that each piece of packaging is only reported and paid for once. PackTotal reduces your liability and EPR costs by calculating the quantity of packaging for which someone else should bear the payment responsibility. PackTotal also correctly excludes packaging which is exported in the calculations.

PackTotal then produces a CSV file in the format specified by HMRC. This file is ready for submission to HMRC or via a compliance scheme.

PackTotal Data Management

So, how do we achieve this magic? Information relating to each product is loaded into your PackTotal database to collect all the necessary sustainability and materials data for every component of your product’s packaging, building a reusable library that saves you time and effort.

The most important details are the product packaging components. Knowing each component’s material, weight, and packaging level is critical. To minimise EPR liability, it is also crucial to know whether the secondary ‘shelf ready’ packaging is branded or not.

The tax liability is generated by cross-referencing the sale details with the product itself. The key points affecting categorisation are the customer size and whether the product is sold for household or non-household use. Other information required for EPR categorisation includes:

brand owner information
whether the product is usually shipped in whole pallets or picked
whether the product is in HMRC’s list of ‘items that commonly end up in public bins

For each sale, PackTotal also calculates the Transit packaging required to ship the pallets of goods and adds this to the totals in the correct place.

PackTotal also records the details of imports and exports to determine which packaging components a company is responsible for as the ‘first legal owner’ in the UK. This also enables the automatic calculation of Plastic Packaging Tax.

PackTotal also records and totals organisational and consumer ‘Self Collected’ waste collections as these are credited against your EPR liability.

How do we make data entry and data loading easy?

With the help of real users, manual data entry has been designed to be as quick and intuitive as possible.

Some companies prefer a more automated solution, so PackTotal can load data from external sources. Initially, product and component data can be loaded into the database. Then, as an ongoing process, sales data can be loaded in from Excel sheets each week or month. This way, a company can see its liabilities on a continuously updated basis.

How do we ensure accuracy?

We appreciate that not all the component, product, and customer data is necessarily present at the start of the process. To assist in data completion, we have an innovative solution called “Missing Data Reports,” which identifies what data still needs to be added to the system before an EPR return can be finalised.

In the screenshot above, you can see the list of components with missing data. The orange cells show the data that must be completed. Manual checking is not required.

What documentation is required?

HMRC requires proof of exemptions, such as PCR declarations. PackTotal can store documents for Components, Products, and Consignments and warn of documents with a limited expiry date.

What else does PackTotal help with?

PackTotal does so much more than just EPR calculations. It deals with Plastic Packaging Tax returns, easy reporting to third parties and calculates annual waste material totals. It allows complete visibility of your product packaging.

In conclusion:

PackTotal ties together the disparate data required to calculate EPR returns accurately. It determines what a company must report and excludes anything that is the responsibility of others in the supply chain, thus minimising EPR liabilities.

If you’re struggling with EPR data contact us to discuss how we can help you streamline your data collection and compliance reporting or to schedule a demo.

How to Effortlessly Master EPR Compliance Without Overhauling Your ERP System

March 6, 2024 by Susie

With the new Extended Producer Responsibility (EPR) regulations, organizations that handle and supply packaging and packaged goods must brace themselves to bear the cost of end-of-life waste disposal.

But cost isn’t the only concern. Alongside the financial implications, the increased scope and granularity of DEFRA’s new packaging reporting parameters add complexity to the compliance process, and companies are realising the enormity of the task at hand.

In the past, many organizations have turned to Enterprise Resource Planning (ERP) platforms to extract data for reporting purposes. However, with the evolving landscape of EPR regulations, relying solely on ERP systems to categorise and extract data for reporting purposes – as many have done in the past – isn’t a viable option.

In this article, we’ll shed some light on the nuances and complexities of EPR packaging reporting and consider some strategies for ensuring you can quickly generate accurate reports when you need them.

Specifically, we’ll explore how incorporating EPR software alongside your ERP platform can speed up and streamline the reporting process.

But first, let’s consider some of the changes introduced by EPR regulations and who is affected.

EPR Ushers in New Producer Responsibilities

Until now, the financial responsibility for waste treatment and recycling of packaging in the UK has been shared across the supply chain. However, with new EPR regulations, the responsibility has shifted to producers.

The term ‘producer’ is quite broad, but if you generate or handle packaging that’s disposed of in the UK, that definition likely includes you.

What type of producer you’re classified as depends on your ‘packaging activity’ or how you introduce packaging into the UK market. EPR rules identify the following six producer types:

Brand owners: Companies that supply packaged goods to the UK market under their own brand.
Importers: Companies that import products in packaging from abroad and then supply these products to the UK market.
Packers/Fillers: Companies that put items or goods into packaging that’s unbranded when it’s supplied to the UK market.
Online Marketplace Operators: Companies operating apps or websites that allow businesses or individuals to supply packaged items or goods to the UK market.
Service Providers: Companies that hire or loan out reusable packaging.
Distributors: Companies that supply unfilled packaging to companies who, in turn, supply that packaging to the UK market.

It’s not uncommon to be involved in multiple packaging activities; for example, larger organizations are often classified as importers and brand owners. This means they need to compile and submit multiple separate reports every year.

Understanding what producer type(s) you’re classified as is just the first step in the reporting process. Complexity quickly starts to mount when you consider the granularity of the packaging data you need to gather, analyse and submit as a formal report to DEFRA.

Why EPR Reporting Can Become a Maze of Complexity

The latest EPR regulations demand comprehensive reporting on packaging materials, weights, waste types and disposal methods across primary, secondary and tertiary packaging. This level of granularity can quickly become overwhelming, especially for large organizations with diverse product portfolios and intricate packaging components.

To ensure accurate EPR reporting, it’s vital to understand where your obligations begin and end. Individual packaging items should only be reported on once by a single party in the value chain.

For each packaging activity that falls under your producer classification, you need to gather and provide extensive information. This includes specifying the base material of each of your packaging components, i.e. aluminium, fibre-based composite, glass, paper or cardboard, plastic, steel, wood or ‘other’ material AND indicating the weight for each component.

Large organizations must also include details of their waste type, i.e. whether their packaging is household or non-household waste, whether it’s often disposed of in public bins or is self-managed, whether it’s a drinks container and if it’s reusable.

A Hair-Raising Scenario

The fact that most products are packaged using more than one type of material makes the process anything but simple. Consider the following example to illustrate the complexity of accurately gathering and reporting on packaging data.

Imagine you’re a beauty products manufacturer and you produce a line of supermarket own-branded hair dye.

From an EPR perspective, the supermarket is deemed the ‘brand owner’, and the product’s ‘primary packaging’ is considered everything the consumer touches. That includes the outer cardboard box and everything inside it – the bottle, tube, caps, gloves, leaflet, etc. All components must be listed individually and also classified as household packaging, as consumers typically dispose of this at home.

As you are not the brand owner, you are not responsible for reporting this primary packaging, but you will need to supply all the details to the supermarket so they can report their obligations accurately.

From here, things can start to get even more confusing.

The products’ secondary and tertiary packaging both need to be classified as non-household packaging as they ultimately end up in the hands of a business end-user, not a consumer, for disposal. However, who has the reporting obligation for these items can vary.

In our example, 20 boxes of hair dye are packed into a separate shelf-ready cardboard box. Who has to report this secondary packaging will depend on whether it has the supermarket’s branding printed on it. If there is no branding on the box, then it could be the responsibility of either the product manufacturer, packer/filler or the importer, depending on where the product was produced.

In the warehouse, 100 boxes of secondary packaging are loaded onto a pallet. A cardboard separator is placed between each layer as additional protection before the pallet’s contents are shrink-wrapped for transport. And you’ll need to remember to include the details of any stickers affixed to the pallets – they’re classified as separate packaging items.

All this additional packaging is classed as tertiary packaging and is marked as non-household packaging.

Note that if goods are imported, this tertiary packaging must be reported under different EPR producer types depending on whether the pallet of goods is imported into a warehouse and then shipped straight out or if it is unpacked and repacked, as in our example.

ERP Platforms Alone Can Only Do So Much

Until now, companies with ERP platforms like SAP or SAGE have been able to leverage these systems’ functionality to create annual waste reports that meet the reporting requirements of existing regulations. However, many find that these ERP platforms lack the specialised functionality required for the granular tracking and reporting of packaging data mandated by the latest EPR reporting regulations.

If you rely on your ERP system alone, while all your data may be there, you’ll likely spend hours or even days exporting it, manually manipulating and checking it and then formatting it to align with third-party compliance schemes and DEFRA’s new reporting requirements.

And with no automation to keep the data collection process rolling forward, you’re destined to reinvent the wheel every reporting period. Not only does this process siphon significant time and resources, but it can also introduce errors or double reporting, putting you at risk of non-compliance.

Another option is to outsource your EPR reporting to a third-party compliance scheme. The downside of going this route is that you’ll likely need to send them files that include proprietary or confidential data.

ERP & PackTotal: A Complementary EPR Duo

As a pioneer in packaging data software solutions, PackTotal has developed EPR reporting software that works efficiently alongside your ERP system, allowing you to collect all your packaging data for every product you produce or handle down to the component level. This helps you avoid misreporting and maintains the accuracy and reliability of your reported EPR data.

At the core of PackTotal’s solution is an intelligent data management system specifically tailored to handle the complexities of packaging data. It stores and maintains sustainability and materials data for every element of your product’s packaging, including components, material type and category, weight, recycling details and evidentiary documentation.

To minimise manual data entry and admin effort, all the data required to calculate Extended Producer Responsibility obligations can be loaded into PackTotal from your ERP system. This has the double benefit of less admin time and effort and greater data accuracy.

A key feature of PackTotal is its data validation capabilities. The system checks for data completeness and flags inconsistencies, ensuring accuracy and integrity. It will ensure you enter all the data required for EPR reporting and provide detailed missing data reports to identify any products or components with incomplete EPR data. This ensures information integrity before submission.

Our software solution is deployed on-premise, so all your proprietary information is securely stored in-house on your company’s own servers. You have complete control over who has access to your valuable data and the ability to share it only with trusted partners.

Packaging reporting is critical, and PackTotal does so much more than just EPR calculations. The reporting and analysis functions give you the capacity to slice, dice and aggregate your data in the most useful ways. PackTotal also calculates Plastic Packaging Tax (PPT) and can produce data files for value chain reporting.

Master EPR Reporting with PackTotal

EPR regulations introduce a new set of reporting requirements for organizations of all sizes. Sorting through your packaging data sets manually to create EPR reports can be tedious. Fortunately, EPR software from PackTotal is here to help, working cooperatively with major enterprise ERP platforms, generating submission-ready reports and simplifying and streamlining the compliance process.

If you’re struggling with EPR data contact us to discuss how we can help you reduce the burden of manual data collection and compliance reporting or to schedule a demo.

Cut Through the Confusion: Expert Answers on UK EPR Packaging Rules

February 16, 2024 by Susie

EPR 101: Demystifying the New Requirements

What UK packaging data must be reported and by when? Who in the supply chain is responsible? Get straight answers to your EPR compliance questions from the experts in this practical video chat between PackTotal’s packaging regulations expert Claire Adams and sustainability leader Joel Tashe from CleanHub.

Here’s what you can expect:

🤔 Plain English on what you need to report and when
💡 Handy tips to get your data in order
💰 Insight on fees and incentives around materials
💻 Software options to make compliance easier
⏰ Guidance on deadlines to avoid penalties

Don’t get left behind on packaging taxes! This talk answers FAQs for producers large and small.

Transcript:

Joel (Host): “Hello everybody. Hi, it’s a pleasure to host yet another LinkedIn live this time with Claire Adams and we’re going to talk about EPR 101, Extended Producer Responsibility. So a bit of a public service announcement before we really get into the conversation with Claire and before I’m going to introduce Claire. Extended Producer Responsibility is a legal topic. We are not talking to a lawyer today, but to somebody who’s very well versed on the topic, so do feel free to ask questions. This is, again, the reason why we do these LinkedIn lives, that we want to bring in experts; we want you to participate. I repeat myself but I love podcasts and sometimes I’m a bit annoyed that I can’t interrupt and ask questions to the guests, so this is why we do the lives. Use the comment functionality if you have questions, just be aware this is not legal advice of any sorts, but we’re also going to talk where you can find more information and with that, very very happy to welcome you Claire. Maybe we start with a quick introduction from your side and then we get into the topic. “

Claire: “Thank you. Thanks for inviting me Joel and looking forward to the chat today. Yes my name is Claire. I work for PackTotal and we’re a software company and we have developed a new data management and compliance reporting software system specifically for the packaging industry and the regulations that are affecting the industry right now. So we came into the market about two years ago when plastic packaging tax came out because of the intricacies of the complications of the calculations and how everyone had to collect that data. We saw a gap that organizations would need some help with those calculations and when we started looking into the industry, we saw that EPR was on the horizon and the extra complications in the data set that would have to be produced. We knew that we had to extend the software to be able to cope with those calculations as well so that’s what we’ve built. We’ve been looking into the industry for a good couple of years now and the technical team have got a very very in-depth knowledge of the regulations and everything that’s required for an obligated producer to be able to produce the reports. I have got a good topline knowledge of it but happy to be here to chat to you today about what it is who’s affected, what people have to do, and like you say, where we can go to get some help and advice to be able to cope with how the obligations and everything that we’re having to do.”

Joel: “Perfect, great. Then let’s dive right in because the title is EPR 101. I’m a complete beginner on the UK EPR system I know about roughly how it works here in Germany but I have no idea in the UK and maybe we play a little game, a bit of a simulation. Say I’m leaving Berlin and move to London for good because it’s the more beautiful city and I’m starting a brand I’m selling fast moving consumer packaged goods. What do I have to do about EPR? When do I qualify for it? What do I need to look out for as a business owner okay?”

Claire: “Well first things it’s good that you actually know that there is something about EPR. It’s a global thing, isn’t it? Lots of countries have started to introduce it and the UK sort of introduced it last year and it’s progressing with what you have to do as a producer. So as a producer, and the term producer is quite broad, so that’s whether you’re going to be a brand owner, a packer filler, an importer, distributor, it’s do you handle packaging that is going to be disposed of in the UK. So we said, yes, you are but your obligations are different depending on the size of your organization, like your turnover and also the amount of packaging that is produced or handled by yourself so it’s like the tonnage of waste. So first things first, you would need to check your obligation, whether you are an obligated producer and you can do that by going on the DEFRA website – we’ve got a link to it on our website – but if I just say it’s if you’ve got a turnover of between 1 and 2 million pounds and you also handle between 25 and 50 tonnes of packaging you will be, well that’s unfilled or filled packaging, you will be classed as a small organization and you will be required to report on your data. You have to register and report. If, however, you now do over 2 million pounds in one year, so this is looking at the 2023 turnover, and you handle more than 50 tonnes of packaging you are a large organization and your obligations are quite significant. Basically EPR has come in as a review to the existing waste regulations so large organizations would have been having to report their waste annually anyway. But EPR has come in to encourage people to look at the full life cycle of your product, so it’s not just what you produce, it’s what happens to it at the end, what happens to it when it becomes waste and is it recycled. EPR is giving the responsibility back to the producers to say you’re going to pay a fee for whatever you produce, There will be a fee to pay to so that the burden of cost isn’t with local authorities, it’s going back to the producers that are putting the packaging on the market.”

Joel: “So that sounds interesting and let’s say since I just started out, I’m one of those smaller organizations, but I am successful enough that I unfortunately have to report – or lucky because it’s good for the environment. So packaging is a very broad topic: what materials? Is it just primary packaging so the actual product packaging? Does it include secondary packaging for when I put it on the shelf? What about my supply chain? What about the tertiary packaging? So if I wrap my pallets in stretch wrap, for example, what goes into the calculation?”

Claire: “They’ve covered everything when we say packaging, so like you say it’s we know you’re a producer but then it’s also what are you producing and what sort of packaging is it, so you’re right, it covers everything. It’s primary, secondary, shipment and tertiary. I don’t know if you want me to go into detail on what, a little bit, what each of those things are just with an example. Perhaps a box of hair care products, the primary packaging is your box of hair dye but it’s also what’s inside it. You know, you’ve got the two plastic bottles with the liquids, the lids, the capsules, the gloves, the paper instructions, that’s all what comes, that’s your primary packaging, that’s what the consumer touches, holds and that’s what we think will be thrown away by a consumer in a household. But then the secondary packaging is how is it sold? So in this instance, let’s say it’s on the supermarket shelf and it’s been delivered in, say 10 boxes of those individual hair dyes, and it comes on a tray. That tray there, that’s secondary packaging and my 10 boxes of hair dye came in boxes of 50 in an outer transit packaging, so that’s your tertiary packaging but it was wrapped in pallet wrap, it had layers in between, it came on a stack. What was that pallet made of, was it wood, was it plastic, is it reusable, is it recyclable, what labels are on this? All of that information has to be reported on from all the way through the value chain and all the way through the cycle. It’s a lot of information to report and what’s also really important to notice, is that each individual piece of packaging must only get reported once. So that hair dye might have come from Germany, it’s been imported into this country, it’s gone around, it came filled and it’s getting delivered to the supermarket so there’s been a few touch points but only one person has to take responsibility for that primary packaging. So it’s important to know through the chain, at what point you’re obligated so the data doesn’t get reported or charged twice.”

Joel: “That does sound quite complicated; so is that something that you and your organization help with in setting up the report?”

Claire: “We do, we do. So our reporting system will allow you to collect all of your information, every product you produce down to the component level. We will be collecting all of your materials data, or for each of the components, all on a database that’s accessible by you or everyone within your organization. You would then turn those components into a product, you would then say what it is in terms of what material it is. You have to report the weight and material so you’d say it’s plastic, it weighs 11 grams, that’s the pot, but it’s got a paper label or a plastic label and it weighs this and it’s a cardboard box and it weighs this and it goes into a pallet which is this. Do you know what I mean? So it logs everything for you. Also important to say who the customer is, what the customer size is, to say it’s not me – it’s going to a large supermarket so they’re the brand owners so it’s their responsibility for reporting the primary and secondary packaging. I’m going to say that I’m responsible for the tertiary and shipment packaging. The pallet was mine, I disposed of that in my organization. The software will do all the data categorization for you. You pump in the data to say what the product is, what it looks like when you put it as a shipment where is it going and then it logs that so at the end of every six months as a large organization, or every year for a small organization, when it comes to the time that I’ve got to report on this data, it’s so simple to be able to do that. At a touch of a button, it’ll just add up for me, what did I do as a brand owner, what did I do as a supplier, what did I do as an online marketplace, and break it down for me in the way that HMRC or DEFRA are asking for. So I want to be able to know what have I done that’s wood, cardboard, plastic, steel, aluminium or other. What have I done and what part of that was primary, secondary, shipment, tertiary and what is the total weight of all of those things. So that when we do have mandatory fees, we’re going to have to report those separately as well, so that they want to be able to do another report to say thanks for that but now I need you to really drill down and go tell me what was PVC, what was black, what was you know, because they need to see that data and they need to be able to then invoice you for what you have put onto the market that is going into the waste stream, that is going to be recycled or not recycled but disposed of by a consumer.”

Joel: “So it sounds incredibly complex and very, very detail oriented. I have a practical question before we get into, I think there is a lot of benefit especially again speaking from an environmental standpoint of that level of detail. Is there a central database where I can say, it’s like okay, it’s a plastic wrap for, I don’t know a chocolate bar, 10g chocolate bar, and this is about as much as the material weighs or do I then have to basically start a lab in my office and start weighing in every single individual item or is there like an orientation framework around.”

Claire: “It depends, if you were the manufacturer of that plastic you would have that information. So you will have somebody in your organization would have that. So that’s interesting you’re saying you know, do I have a central database, your organization might have the information spread out about six or seven different places. To have it in a hub would be ideal but let’s just say you’ve bought that in so your supplier should have that information and you have to ask them for it but at least once you’ve asked the question once, you bring it into your system, log it and it’s logged for everyone to know and see. And then for when you pass the information on, so if you were the wholesaler or distributor of that, you’d have that information to be able to pass on to the next people. “

Joel: “And another practical question because it sounds like I can just negotiate a lot with all the people in my value chain and say it’s like I think the responsibility is on you, I think it’s on you, like it starts to be a bit of a finger pointing exercise or is there a hierarchy? So if I’m the brand owner, let’s say and I run a direct consumer business and I sell shampoo, I import the packaging maybe from China, the product is filled in, I don’t know southern Germany, and then it ships into the UK and I sell it online but I also have a retail relationship, let’s say with Tesco because I’m very successful. Who says who’s responsible then? Isn’t that like a massive communication issue also?”

Claire: “So DEFRA have said who’s responsible by saying Tesco’s are generating over 2 million pounds and dealing with over 50 tonnes: they are a large organization. As soon as their logo goes on this shampoo they’re responsible for it. They’re responsible for the primary or whoever’s logo is on that packaging, they’re responsible as long as they are a large organization. If you are dealing, if you’re a brand owner that’s a small organization, you’ve put the product onto the market so you are responsible for it in terms of reporting but in terms of a fee, you’re not. There won’t be any modulated fees that you’re responsible for.”

Joel: “Interesting. So it does sound like I would definitely contact you if I would start a brand because I would want to have my data centralized so that’s already clear. The other question and this is where we’re probably then also stepping a bit into a grey zone, is how like at this level of detail, who’s controlling that and what are the fines if I don’t comply, because I can just say look I’m making more than 2 million but I don’t produce 25 tonnes, prove me wrong.”

Claire: “Well this came up in the chat we had with DEFRA doing monthly forums, business readiness forums so we had one this week and it was great because we met the scheme administrator who’s supporting DEFRA in actually implementing this. That question came up to say, well hold on a minute, like you say are Tesco’s going to actually really want to take the brunt of this 3 billion pounds worth of fees? What happens if only one person says that they are a large organization? It’s like don’t worry, they have got things in place to know because remember this is an addition to the waste regulation that’s been running for 15-17 years. People have already said what they’ve been doing turnover and wastewise, so it’s going to look a bit strange if they suddenly drop off the face of, you know, no more reports. There will be fines in place so we’re saying the deadline, we talked, and said the first deadline for large organizations to produce their annual data for 2023 is the 1st of April. We were supposed to do six months of it back in October but let’s just say 1st of April is your deadline but they have said no penalties will be enforced until the 1st of May, I think May, let’s say May, but I don’t know what that penalty is. But you know, we have seen the Environment Agency penalizing people for not conforming to the current regulations. If you haven’t been doing the data in the way that we’re asking you to, or if you haven’t been sticking to a responsibility of recycling as much as you said you would or should, you will get a fine so we we’ve seen that happening so people have to be aware that there are implications for non-compliance. It’s not just paying for more than you should, there is also the other end of, if you don’t report accurate data correct data or if you’re not complying to any of the things that DEFRA are asking you to do that there will be penalties and fines in place but don’t know what they are yet.”

Joel: “Interesting and my assumption, correct me if I’m wrong, so if I have to break this down into the different material categories and says like this can be recycled, this can’t be recycled, this is cups that are recyclable, maybe this is not, I hope that the regulation is designed in a way that it promotes recycling so if I put out material that is fit for the circular economy that can have a second life then I will have lower fees. If I put out multi packaging that I can’t recycle that has to be disposed of then I would have to pay a bit more, is that a correct assumption?”

Claire: “It is absolutely. I mean that’s one of the main focuses is, this is environmental policy to encourage producers to think about the whole life cycle and to produce products that are going to be either recycled or use materials that have come from recycled materials. So there’s a RAM methodology which is, I’m reading it here, Recyclability Assessment Methodology, which hasn’t been defined yet but it’s in discussions but let’s just say it’s totally encouraging that they want people in the industry to use materials that are better for the environment, in terms of using materials that are using recycled content and can be recycled. The fees, it’s called modulated fees for that reason, so I think they in discussions with about 13 materials at the moment and let’s just look at plastic as one of those examples. It’s going to encourage you through the fees system or the modulated fees system to say if you, let’s say the base fee is here, PVC has a modulated fee of 1.2 so it’s going to charge you 20% above the base rate for using a product that we deem to be not great and it will just get worse and worse and worse for what they deem as bad materials. And then there’ll be an offset to say, well underneath the base rate, if you are using packaging that comes from seaweed, anything like this you know comes from a great source and can easily be recycled, then it might be a 0.8 so it’s 20% more or 20% less so it’s totally going to go in the similar way to Plastic Packaging Tax. The fee you pay will be dependent on how environmentally friendly those things are but we haven’t heard yet exactly which products are coming under modulation. We haven’t heard yet exactly how they’re going to be doing the RAM methodology, you know how are they going to really class what is recyclability, but at the moment it’s just important, it’s just the large producers that are going to have this modulated fees and it’s only household packaging that’s the focus at the moment and the focus is on recyclability. But as EPR comes out and we move in the next 3, 5, 10 years, their focus might not be on just recyclability, it might be on reusability or reducing the size of thing to say you know, that’s a waste, a total waste of packaging, there’s x amount of air in that or why have you put five pieces of cardboard around something or why did you use cardboard when actually plastic would have been better in that scenario. What are the models that we can use and that’s in discussion at the minute with the, like I said, with the scheme administrator and the Steering Group with DEFRA that’s all coming out.”

Joel: “I love the concept even though it is complicated or it sounds like it’s quite a complicated or a complex task to calculate or that the direction where that is going, to me personally, sounds fantastic because, if you behave well in line with nature, you pay less, if you don’t, you pay more. I think the biggest question then is going to be, what’s the price point of the actual packaging right? So if I can procure the, let’s say, more sustainable, better recyclable packaging at maybe a little bit higher price than the less sustainable one, the effects need to grip right because else from a bottom line perspective, I can then still say it’s like all right. I might accept the higher fee that I have to pay through EPR but for that I have way lower procurement price for my packaging so if somebody’s just looking at it from a financial perspective right, so I don’t want to be the person that has to design all their policies because it does sound like a very complex task.”

Claire: “Well they’re using, you know, they’re taking advice from the industry you know the whole packaging value chain is complicated and so the people that are making these decisions, yes it’s the government, but it’s really being driven, it’s being value led by the producers that are going to be responsible for paying it so they’re going to have a massive, massive amount of input into well, how is it actually going to run. You know, is that fair? Why am I being asked to change to this when like say economic side of things going I can’t source anything or when I do try and source it, it’s five times more expensive so I’m not going to use recyclable materials, fine me. So I think the whole point of EPR is not a massive tax on people, it’s not just to collect amount of money, it really is to encourage well, just you know, for organizations to look at what do you pack, what packaging is going on the market. Have you made the best choice for you financially or environmentally because now if you’re going to have to think about the end of life, where is it going, who’s going to pick up the cost for that. It just makes you start thinking about it but hopefully within the next few years that, you know, there’ll be the money that is going to come in from EPR, it’s estimated I think, they said let’s say 2, I think they currently get 200 million from producers paying the annual waste fees and it’s projected to maybe be 3 billion pounds that is going to be collected through EPR. And this is to encourage the circularity, you know, we’re going to address the flow of materials they want to be able to make sure that we have got the infrastructure within the UK that if we say it’s recyclable, we don’t mean just in one local Authority, it’s or it’s recyclable but not at home, not at curb side you’ve got to then go and take it to the recycling centre down the road, a tip or you know but it’s us as consumers to get into that habit you know. Drink a lot of wine, I go to the glass recycling, you know, and that’s just become habit isn’t it? You eat your crisp packets – we go through an awful lot, I’ve got three children – so be able to recycle those with my curb side would be great but you know we’re not quite there yet, but we should hopefully get there if we can get this amount of money and the infrastructure and it’s to go round and round in that circle.”

Joel: “But it sounds like they are setting the rails really well and maybe a final question from my side. I also saw that the UK introduced the plastic tax. Is that coming on top of EPR?”

Claire: “It is yes so you will be responsible for both. So Plastic Packaging Tax you have to report four times a year. If you are a large organization for EPR, you’re going to have to do it another two times a year for this and, yes, you will be liable for both taxes. But that’s why I’m saying with the modulated fees, maybe they’ll take that into account that if you’re already, we’re already looking at plastic, what parts of those plastic are we going to look at in terms of the modulated fees.”

Joel: “Okay so I think even though there’s a lot of work to do this is clearly a sign in the right direction so I’m crossing my fingers that all will go well. My takeaway is if you’re a large organization meaning you make more than two million in turnover and you have more than 50 tonnes, watch out for the 1st of April make sure that you hand in your data else you’re going to be in trouble. If you need help with that contact Claire. If you listen to this not live but, I don’t know on YouTube etc., we’re going to link the contact details, we’re going to link PackTotal that can help you produce that reporting and I think there’s no questions from the audience so that means we answered all of them I think else you can find Claire on LinkedIn I think it’s fine to contact you to message you if there’s any questions and thank you so much. I think that was a fantastic and very very insightful session. I would feel a lot more comfortable now launching a brand in the UK but I might just continue doing what I’m doing and leave that stuff to those. Claire thank you so, so much and have a great day.”

Claire: “And you.”

Take Control of Compliance with PackTotal

UK packaging regulations ushering in new complex reporting requirements, fees, and deadlines. Don’t let your business lag behind. Take control with PackTotal software – designed specifically to manage UK packaging data and taxes.

Book a demo to see how PackTotal can:

Seamlessly consolidate your packaging data
Automate Material and Tonnage reporting
Calculate budget impacts of modulated fees
Generate required reporting with one click
Ensure your business is audit-ready 24/7

Don’t wait to optimize for new regulations and deadlines. Future-proof compliance now. Contact us today for a demo.

EPR Deadline Looming: Is your Data Prepared for April 1st?

January 23, 2024 by Susie

While the acronym ‘EPR’ might only be three letters long, the regulation spells major change for UK businesses. The new Extended Producer Responsibility (EPR) Framework builds on the country’s existing packaging and waste regulations to create a more stringent compliance regime for producers and users of certain items.

Specifically, EPR regulations require businesses to record and report on the packaging they supply, use and waste. This includes the type of packaging they use, how many tonnes of it and where it goes. Larger businesses may also bear the costs of recycling or sending waste to landfills, a concept known as modulated fees, which will be introduced in 2025/2026.

The phased implementation of EPR began at the end of 2023, and large organisations must submit their 2023 data by 1 April 2024.

Despite the first EPR reporting deadline being just around the corner, research suggests most businesses are inadequately prepared, mainly due to suboptimal or non-existent packaging data collection processes.

Time is running out to ensure you have end-to-end visibility of your packaging data. In this article, we’ll delve into some of the details of the new EPR scheme and consider how the right technology can remove the effort and risk associated with gathering packaging data the traditional, manual way.

What is the New EPR Framework and What Does it Mean for My Business?

EPR is a waste disposal scheme designed to make businesses bear the cost of end-of-life waste disposal rather than local authorities. It aims to incentivise companies to use less packaging, use more recyclable packaging and meet higher recycling targets.

The breadth of those impacted is broad. From retailers and restaurants to car manufacturers, many organisations now need to provide authorities with granular insights into their packaging data. You need to collect and report on your packaging data if:

You’re an individual business, subsidiary or group (charities are excluded)
Your annual turnover exceeds £1 million or more
You were responsible for more than 25 tonnes of packaging and/or packaging materials in a year.

Your packaging data submission needs to include the following information:

Packaging activity: How you supplied the packaging
Packaging type: The type of waste the packaging will become at the end of life, for example, household or non-household waste
Packaging class: If the packaging is primary, secondary, shipments or tertiary
Other: Packaging material and weight

Deadlines for reporting packaging data vary depending on whether authorities classify you as a large or small organisation. HMRC’s official guidance on the EPR regulation is available here.

EPR Preparedness is Lacking

Let’s take a moment to consider UK businesses’ EPR readiness. Despite the looming reporting deadline, research undertaken in early 2023 suggests that their preparedness for EPR is significantly lacking. At the time of the study:

Three in every five businesses surveyed didn’t currently collect data on packaging waste, let alone report on it.
86% of respondents had yet to establish their data collection processes fully.
42.9% of respondents rated themselves as unprepared but aware of the changes brought about by the latest EPR regulations.
14.3% of those responding admitted to being unprepared.

The Perils of Manual Packaging Data Collection

Using Spreadsheets is old fashioned and error prone.

Manipulating data the old fashioned way using spreadsheets is prone to error.

As we’ve explored, EPR regulations require detailed data submissions. This means if you don’t supply the necessary packaging data, or it isn’t sufficiently precise, there could be cost implications.

Collecting data manually (on paper or by using spreadsheets) isn’t a viable option. Besides being laborious and time-consuming, manual data entry processes are laden with the risk of errors. Research on manual data entry work reveals an average human error rate of 1%. The error rate can increase if the data being entered is complicated, if the user is tired or in a hurry, or if somebody simply has handwriting that’s difficult to read.

Another study found that when performing data entry tasks related to spreadsheets, humans will average an accuracy rate of around 95%, even when dealing with small spreadsheets. When the complexity of the spreadsheet increases, the chance of a processing error is almost 100%.

How PackTotal Can Help

When it comes to EPR compliance, as with most things, those who are best prepared are also best placed to succeed. And your preparation starts with organising the process of locating, verifying and collating your packaging data.

PackTotal’s EPR system is designed to do just this. It lets you gather and collate your packaging information and quickly generate accurate EPR submission files that meet HMRC’s precise specifications. Our solution uses a database to collect and manage materials data for every component of a company’s product packaging across different departments. All data is securely stored in a central repository.

The PackTotal EPR Edition Includes

EPR Data Categorization, Calculation and Reports: Accurately splits the data into the reporting categories required by HMRC. Full calculation of the Extended Producer Responsibility figures and production of submission files.
Automated EPR Report Generation In-house: It enables the extraction of essential data from your packaging components, streamlining data collection and report generation.
Efficient Data Management: The software excels in collecting, organising, and managing crucial data for all packaging components, featuring a secure, centralised database.
Robust In-house Data Storage: PackTotal prioritises the security of your proprietary information by storing it directly on your company’s servers.
Seamless System Integration: The PackTotal Database integrates effortlessly with your existing IT infrastructure, like ERP or supply chain management systems, enabling efficient data exchange and workflow.
Data Validation and Audit Support: PackTotal conducts thorough data validation checks to guarantee the accuracy and completeness of your EPR reporting data and supporting documentation.
Record and calculate Nation Data: PackTotal records and calculates data based on where in the UK the packaging has been sold, hired, loaned, gifted, or discarded, integrating this information into the EPR data submission.
Self-Managed Waste Collection Calculations: The software calculates both Organizational and Consumer Self-managed waste, potentially offsetting household packaging obligations and reducing waste management fees.

With PackTotal, you’ll be on track to fulfil your EPR obligations and make data submissions to HMRC on time, every time without the stress.

As always, we’d love to hear your thoughts. Please share your experiences, ask a question or simply provide your thoughts on the new EPR data collection and reporting mandate. If you’d like to discuss your requirements, request more information or arrange a demo, please get in touch.

Understanding Extended Producer Responsibility

September 25, 2023 by Susie

Understanding EPR: The New UK Legislation

The UK is facing a waste crisis with over 220 million tons of waste produced annually. This has sparked a new wave of environmental policies, including the recently introduced Extended Producer Responsibility (EPR) legislation.

Extended Producer Responsibility measures in the UK are now being phased in to hold product manufacturers and organisations responsible for their packaging waste, from production to disposal.

In this blog post, we will explore the new UK EPR legislation, see who is obligated and look at the steps you must take to comply.

What is Extended Producer Responsibility?

Extended Producer Responsibility (EPR) is a new UK legislation that will replace the current Packaging waste Regulations with a phased implementation from the end of 2023.

EPR requires businesses to record and report information on the amount of packaging they supply, use and waste, and some larger organisations will also pay the costs associated with recycling or sending to landfill or energy recovery.

It encourages producers to design products with recyclability and end-of-life management in mind to ensure that as much packaging material as possible is recycled and that adequate funding is raised to cover the cost of collecting and recycling packaging material when it becomes waste.

When does EPR come into effect?

Obligations to report packaging data passed into law in Feb 2023, and your business should start preparing now to capture your packaging data.

Large producers must submit a report every six months.

The 2023 reporting data is required for January to June and July to December and must be submitted separately.

The first data reporting deadline has been delayed from 1st October 2023 to 31st May 2024.

Small producers submit data once per year, which should be submitted by 1st April 2024 to cover 2023 packaging.

Note: If your organisation is based in Wales, large or small, your data must be submitted by 1st April 2024.

The deadline for submitting data is 1st April 2024, but no penalties will be enforced for reports received before 31st May 2024.

Regulators have indicated that if you can submit your data by the original deadline of 1st October, or as soon as possible, it is strongly encouraged to do so.

If your organisation is required to report Nation Data, you must submit this information for the 2023 calendar year by 1st December 2024.

Proposed EPR Timeline

2022 – Regulations in place
2023 – Start collecting packaging data from 1st January. Recyclability assessments are completed, and producers start reporting their packaging data.
2024 – EPR introduced the first payments of fees dues from April 2024, based on recyclability assessment data completed in 2023.
2025 – Modulated fees become fully operational.
2026 – Mandatory labelling is introduced for packaging except for films and flexibles.
2027 – Films and flexibles to be collected by local authorities and be obligated under the labelling system.

Information about modulated fees

Originally set for October 2024, the implementation of EPR fees to local authorities has been deferred for a year and will now take place in October 2025. The government have said that it would use the extra year to discuss the scheme’s design with the supply chain and reduce costs wherever possible.

As of yet, it hasn’t been announced what the fees will be however the fees will vary depending on the materials you report.

In future, the waste management fee will also vary depending on how easily the packaging can be recycled. The fees will be lower if you use packaging that is easier to recycle.

Ultimately, the best way to prepare for EPR and the associated fees is to ensure you have a thorough understanding of the recyclable potential of the packaging you handle. Then, use the reporting data you collect this year to pre-empt costs and plan more sustainable solutions for your packaging.

Is your business obligated under EPR?

Your business has a packaging waste obligation if ALL of the following points apply:

Its annual UK turnover exceeds £1 million, AND
It has a physical presence in the UK, AND
It is responsible for more than 25 tonnes of packaging and/or packaging materials in 2022.

The actions that will need to be taken depend on the size of your business as the scheme is set to impact smaller and bigger businesses differently so you will also need to check if you are classed as a large or small organisation.

You will be classed as a small organisation if your annual turnover is between £1 million and £2 million and you are responsible for supplying or importing between 25-50 tonnes of empty packaging or packaged goods in the UK. You will be classed as a large organisation if you have an annual turnover above £2 million and you are responsible for supplying or importing more than 50 tonnes of empty packaging or packaged goods in the UK.

For more information about the obligation criteria and the requirements for each size of organisation we have more in depth info here: EPR – Is your business obligated to report on packaging waste?

What do you need to do to comply with EPR reporting?

There are increased reporting requirements for producers under the new EPR regulations.

Organisations will now have to collect and provide detailed reporting on the packaging they produce and how the waste will be managed.

If you are obligated for EPR, you need to start to record your data on the quantity of packaging by weight from Jan 2023.

What data will you need to collect?

The packaging data submission must include the following information about the:

Packaging activity – this is how you supplied the packaging.
Packaging type – the type of waste the packaging will become at the end of life, e.g., if the packaging is household or non-household waste.
Packaging class – whether the packaging is primary, secondary, shipments or tertiary.
Packaging Material and weight

For the first year, companies will have to report on aluminium, steel, glass, wood, plastic, paper, cardboard, fibre-based composites and other materials like industrially biodegradable packaging.

How PackTotal software can help

Reporting under two waste management schemes and navigating the new EPR regulations can feel a bit overwhelming and an administrative burden. PackTotal software is designed to make your EPR responsibilities easier for you.

Installing our innovative packaging data management software enables you to gather, manage, and view all the key packaging information, such as sustainability and material specifications data for every component of your product’s packaging.

With PackTotal’s Extended Producer Responsibility system, you will have the capability to collate your packaging information so that you can produce EPR submission files which meet HMRC specifications, thus fulfilling your EPR obligations and facilitating quick and easy data submissions to DEFRA or third parties.

We have created an alternative method for businesses looking for help to manage their business information in-house and create packaging data reports with added security.

If you would like to discuss your requirements, request more information, or arrange a demo please contact us, we will be more than happy to help.

For the HMRC’s official guidance on the Extended Producer Responsibility regulation, visit www.gov.uk/guidance/packaging-waste-prepare-for-extended-producer-responsibility

EPR: Is Your Business Obligated To Report Packaging Data?

August 3, 2023 by Susie

If your business uses, handles, imports or generates packaging, then you are likely to be affected by the new Packaging Extended Producer Responsibility (EPR) legislation.

DEFRA’s newly introduced Extended Producer Responsibility scheme makes businesses responsible for paying for the packaging waste they generate and the packaging they place on the market. This means that manufacturers, importers, and retailers have new and challenging obligations to fulfil.

As a business, it’s crucial to understand your obligations under these new regulations to avoid potential penalties and maintain your reputation as an environmentally responsible organisation.

In this article, we’ll guide you through all the information you need to determine whether EPR impacts your business and the steps you may need to take to comply with these new rules.

Is your business obligated under EPR Regulations?

Your business is obligated to collect and report packaging data under EPR if it meets ALL of the following criteria:

you’re an individual business, subsidiary or group (but not a charity)
you have an annual turnover of £1 million or more (based on your most recent annual accounts)
you were responsible for more than 25 tonnes of packaging
you carry out any of the following packaging activities:
- supply packaged goods to the UK market under your own brand
- place goods into packaging that’s unbranded when it’s supplied
- import products in packaging
- own an online marketplace
- hire or loan out reusable packaging
- supply empty packaging

Understanding Qualifying Packaging Activities

Under the new EPR regulations, your business is obligated to report packaging data if you carry out any of the following packaging activities:

Supply packaged goods to the UK market under your brand – if your business sells products or goods in packaging labelled with your brand and supplies them to the UK market, you are considered a packaging producer under EPR. This includes goods produced, packed or imported by third parties on your behalf.
Place goods into packaging that’s unbranded when it’s supplied – if you place goods into packaging you may need to report under EPR. This could be goods you packaged for your own organisation or another organisation.
Import products in packaging – you may be liable for EPR if your organisation imports packaged products from outside of the UK supplies these products to the UK market. You may be obligated if you sell imported goods packed or filled by a UK third party on behalf of a company not established in the UK. You may need to take action even if you discard packaging before selling the goods.
Own an online marketplace – online marketplaces are defined as websites or apps that allow non-UK businesses to sell their goods online to UK consumers. Even if you don’t handle the packaging directly, you will be responsible for the packaging generated by these activities if you own such a marketplace.
Hire or loan out reusable packaging – if your business provides reusable packaging, such as pallets or crates, to other companies on a hire or loan basis, you are considered a packaging producer for EPR reporting. A business must record data regarding the first time that item is placed onto the UK market.
Supply empty packaging – you may be obligated if you manufacture or import empty packaging such as boxes, bottles, or containers and then supply it to a business that is not classed as a large organisation.

Reviewing your business packaging activities carefully is crucial to determine if they fall under these categories. Even if packaging is not your core business, you may still have EPR obligations if you engage in any of these activities.

Determining your organisation’s EPR classification

The level of your EPR obligations depends on whether your business is classified as a small or large organisation. Small organisations have an annual turnover between £1 million and £2 million and are responsible for supplying or importing between 25-50 tonnes of packaging. Large organisations have an annual turnover above £2 million and handle more than 50 tonnes of packaging.

Producers within these thresholds will have an obligation to report “placed on the market” data, meet recycling obligations, and pay disposal costs for Local Authority collected waste.

Those who have a “Reporting Only” obligation must register with their regulator, and collect and report information on the packaging that they supply to the UK market.

Those who have a ’Full Obligation‘, will also have to meet further obligations based on this data.

Key obligations for small and large organisations:

Small organisations must:

Record data on all empty packaging and packaged items supplied through the UK market from either 1st January 2023 or 1st March 2023. You do not currently have to report data, but you will need to in the future.

Large organisations have additional obligations, including:

Create an account for your organisation to report your packaging data.
Pay a waste management fee.
Pay scheme administrator costs.
Pay a charge to the environmental regulator.
Purchase packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNS) to meet recycling obligations
Report data about empty packaging and packaged goods you supplied or imported

Nation of Sale Obligation

Nation data is information about which nation in the UK packaging is supplied and which nation in the UK packaging is discarded. Producers will have an obligation to report where packaging is disposed of, broken down by nation within the UK. Not all producer types will be obligated for both sets of obligations.

What do you need to do to comply with EPR?

The key obligations under EPR are that producers must register their organisation, report packaging data, and ensure their products are appropriately collected, recycled, or recovered.

There are increased reporting requirements for producers under the new EPR regulations. Organisations will now have to collect and provide detailed reporting on the packaging they produce and how the waste will be managed.

Reporting periods for 2023

If you have all the required data recorded from 1st January 2023, you should report this data.

If you do not have all the required data recorded from 1st January, you must report all of your data from 1st March 2023. If you report data that covers a period starting from 1st March, this will be used to calculate a full year’s worth of data.

Reporting periods for 2024

Some of the rules for reporting data are changing from 2024 onwards.

If you have all the data under the new rules for 2024, you should report it in two batches:

report your January to June data from 1st July 2024
report your July to December data from 1st January 2025

If you do not have all the data required under the new rules, you should still report in two batches:

do not report any data relating to packaging supplied between 1st January and 31st March 2024
report data collected under the new rules from 1st April to 30th June – do this from 1st July 2024
report your 1st July to 31st December data from 1st January 2025 – this data must follow the new 2024 rules

If you do this, the data from the two submissions will be used to calculate the three missing months (January, February and March 2024).

Deadlines for reporting packaging data

Small organisations should:

collect your 2023 packaging data – you do not have to report it
collect your 2024 data and submit it by April 2025

Large organisations

In England, Scotland and Northern Ireland, you should have submitted your data by:

1st October 2023 to report for January to June 2023
1st April 2024 to report for July to December 2023

In Wales, you should have submitted data for July to December 2023 by 1st April 2024. You can include data from January to June 2023 if you have it.

The regulations lay out these deadlines. You should make your best effort to meet them, but no enforcement action will be taken regarding late submission if your data is submitted by 31st May 2024.

Consequences of EPR non-compliance

Failing to comply with EPR regulations can result in significant penalties, damaging your reputation and financial standing. By understanding your obligations and implementing effective packaging data management processes, you can avoid these consequences and demonstrate your commitment to environmental responsibility.

How PackTotal simplifies EPR compliance

Managing complex packaging data and reporting under two waste management schemes can be challenging for businesses. That’s where PackTotal comes in. Our innovative software solution is designed to streamline your packaging data management process, making EPR compliance simple and efficient.

PackTotal’s Extended Producer Responsibility system is an alternative method for businesses looking for help to manage their own business information in-house and create packaging data reports.

With PackTotal, you can collate your packaging information so that you can produce EPR submission files that meet HMRC specifications, thus fulfilling your EPR obligations and facilitating quick and easy data submissions to DEFRA or third parties.

Don’t let the complexities of EPR compliance overwhelm your business. By investing in PackTotal, you can simplify your EPR compliance process and enhance your overall packaging data management strategy, leading to improved efficiency and cost savings.

Contact us today to learn more about how PackTotal can help your business meet its EPR reporting requirements and streamline your packaging data management process. Our team of experts is ready to provide you with a personalised demo and answer any questions you may have.

For full information and guidance about the Extended Producer Responsibility regulation, visit https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-who-is-affected-and-what-to-do