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.