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As a large or small organisation affected by EPR for packaging, you must collect and report data about the packaging you supply within or to the UK market.听

Find out if you鈥檙e affected by EPR for packaging rules.听

The data you report will be used to calculate your recycling obligations and any waste disposal fees.听

Data you must collect and report听

The data you must collect and report depends on whether you鈥檙e considered a large or small organisation (also referred to as large and small 鈥榩roducers鈥� under EPR). Check if you鈥檙e considered a large or small producer. 听 It also depends on whether the packaging is supplied by an organisation that鈥檚 established in the UK.听

Large producers听

You must report:听

• packaging activity data 鈥� for example, supplying under your brand, packing or filling, or importing听
• packaging type data 鈥� for example, if the packaging is household or non-household听
• packaging class data 鈥� whether the packaging is primary, secondary, shipment or tertiary听听
• packaging material and weight data听

You must also collect information about the recyclability of some packaging. Find out about the recyclability assessment methodology (RAM).听

You may also need to report nation data. This is information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in.听

Small producers听

You must report:听

• packaging activity data听
• packaging class data听
• packaging material and weight data听

You do not need to:听

• report drinks containers as household and non-household - you need to report the weight and number of units only听
• split plastic into 鈥榬igid鈥� and 鈥榝lexible鈥� packaging material - you just need to report it as 鈥榩lastic鈥櫶�

All the differences are explained in more detail in the relevant sections of this guidance.听听听

What 鈥榚stablished in the UK means鈥櫶�

An organisation is established in the UK if the registered office, head office or principal place of business is in the UK.听听

An organisation can also 鈥榚stablished in the UK鈥� if it just has a branch or postal address in the UK. This can be:听听

• a PO box听
• an office听
• a warehouse听
• domestic premises that are used for business听

This is true even if the registered office, head office or principal place of business is outside the UK.听听听

Reporting deadlines听

Large and small producers must report their 2024 data by 1 April 2025.听

Read more guidance about reporting dates and deadlines for large and small producers, and what to do if you miss a reporting deadline.听

Reporting nation of sale data and self-managed organisation waste for 2024 to 2026听

The environmental regulators have issued a statement on nation of sale data and data about self-managed organisation waste. {:#rps}听

This only applies to nation of sale data and data about self-managed organisation waste. It does not apply to any other data you must collect for EPR for packaging.

Read the regulatory position statement to understand how this affects your data submission.

Report packaging activity data听听

As a large or small producer you must report how you supplied packaging within or to the UK market under the following categories听 鈥� you can report data under more than one category if this applies:听

• supplied under your brand听
• packed or filled听听
• imported (or as 鈥榝irst UK owner鈥�)听
• supplied as empty (for example, if you鈥檙e a distributor)听
• hired or loaned (service provider)听
• supplied through an online marketplace that you own听

鈥楽upplied听 under your brand鈥� packaging听听

This includes any packaged goods supplied under a brand that you own. A brand includes any of the following:听

• a name听
• a trademark听
• any distinguishing mark听

This applies to all filled packaging, where one or more of the pieces of packaging displays the brand you own.听

For example, you may supply a ready meal inside an unbranded plastic tray with film, with a branded cardboard sleeve. In this instance, the plastic tray and film should be included as part of the data you report in the 鈥榮upplied under your brand鈥� category.听听听

Primary, secondary, shipment and tertiary packaging can all be classed as 鈥榮upplied under your brand鈥� packaging.听听听听

If you pay another organisation to carry out part of the supply chain for you, you should still report any packaging that鈥檚 supplied听 under your own brand. This is the case even if you paid or licensed another organisation to:听听

• produce听 goods that you鈥檝e gone on to supply under your brand听
• pack goods that you鈥檝e gone on to supply under your brand听
• supply your branded goods to the UK market听
• import your branded goods for you听

If another organisation uses your brand under a licence agreement, you are responsible for the branded packaging they supply in the UK. unless it is imported, and you were not responsible for the import, in which case the other organisation should report this packaging as 鈥業mported鈥� packaging.听

For packaging with more than one brand听听

Sometimes packaging around a sales unit displays more than one brand. If this is the case, the organisation that must collect data is the owner of the brand that supplies the sales unit when it is filled for the first time.听听

If a sales unit contains packaged items with another organisation鈥檚 brand, you should only collect data for the packaging you鈥檝e added to the sales unit that has your brand on it, and any other unbranded packaging. However, if there are imported products inside, you may have to report them as 鈥榠mported鈥� - see the guidance on imported products below.听

For example, if you supply food hampers bearing your brand, you only need to collect data for the hamper and other packaging you add (such as straw, tags, ribbons or bows). You do not need to collect data about any items contained within (such as wine, biscuits or cakes) if they display another organisation鈥檚 brand, unless you鈥檝e imported that packaging.听听

There are detailed illustrations and examples in the 鈥榓greed positions and technical interpretations鈥� guidance, produced by the environmental regulators. It is currently stored on .听

鈥楶acked or filled鈥� packaging听

Report any unbranded packaging you pack or fill.听听

You should report branded packaging that you鈥檝e packed or filled if all the following are true:听听

• there鈥檚 only a packaging manufacturer鈥檚 brand on the packaging听
• the brand does not relate to the product inside听
• you do not own the brand on the packaging听

For example, if you pack and fill Jiffy bags with a product, you鈥檇 report the Jiffy bags.听听

You should also report branded packaging that you鈥檝e packed or filled if either of the following are true:听听

• the brand on the packaging belongs to an organisation that is not established in the UK听
• the brand on the packaging belongs to a UK organisation that is not a large organisation听

鈥業mported鈥� packaging听

You must report filled or unfilled packaging that you have imported and gone on to supply or discard in the UK if: 听

• it鈥檚 unbranded after it鈥檚 imported听
• it鈥檚 branded but the brand owner is not established in the UK听
• it鈥檚 branded, but the brand owner is not responsible for the import听
• you supply to an organisation in the UK that is not classed as a large organisation under EPR for packaging听
• you import it into the UK, filled or unfilled, and discard without supplying within the UK or exporting听

听You do not need to report filled packaging as 鈥榠mported鈥� if it鈥檚:听听

• branded, and you鈥檝e imported it on behalf of a brand owner that is established in the UK and is a large organisation听
• unbranded, and you go on to supply it to a large organisation that applies its brand to them before supplying them on听

The large organisation must report these as 鈥檚upplied under your own brand鈥�.听

There are detailed illustrations and examples about importing in the 鈥榓greed positions and technical interpretations鈥� guidance, produced by the environmental regulators. It is currently stored on .听听

Importing packaging: secondary and tertiary packaging听

If you import filled branded packaging, you do not have to report secondary and tertiary packaging if all the following are true:听听

• it is branded听
• the brand owner is a large organisation, established in the UK听
• the brand owner is responsible for the import听

See the section 鈥楶ackaging class data鈥� on this page for more information about primary, secondary, tertiary and shipment packaging.听听听

Packaging that鈥檚 packed or filled by UK third parties听

You鈥檒l also have to report if your organisation sells products to end users where the following are true:听听

• the brand owner is an overseas business that is not established in the UK听
• a UK third party packs or fills a product into the brand鈥檚 packaging before it comes to you 鈥� they may also manufacture the product听
• the overseas brand owner owns the packaging while it鈥檚 being filled and before you purchase it听

You are 鈥榝irst UK owner鈥� of these packaged products. Report this packaging under the 鈥榠mported鈥� packaging activity.听

For example, a French company purchases bottle packaging from a UK supplier. They have the packaging sent to a UK company. The French company sends over shampoo in bulk to the same UK company, who put it in the packaging and send the packaged shampoo to the French company鈥檚 UK customer, a supermarket. This supermarket is 鈥榝irst UK owner鈥� - they are responsible for the packaging.听听

鈥楽upplied through an online marketplace that you own鈥� packaging听听

Under EPR for packaging, you鈥檙e classed as owning an online marketplace if you operate a website or app that allows non-UK businesses to sell their goods into the UK.听听

If you own an online marketplace, you should report any filled or unfilled packaging supplied by non-UK businesses through the marketplace in this category. You should only report packaging supplied to the UK market from abroad.听听

You must also send a description of the methodology you鈥檝e used to collect your data to the relevant environmental regulator before submitting your first set of data.听听

Find out how to create and submit your methodology.听听

If your organisation owns a website that supplies goods from UK organisations only, this is not classed as an online marketplace.听听

鈥楬ired or loaned鈥� packaging听听

If you hire out or loan out reusable packaging, you should report that packaging in this category. You only need to report this packaging the first time it鈥檚 supplied.听听

鈥楽upplied as empty鈥� packaging听听

Distributors who manufacture or import unfilled (branded or unbranded) packaging must report it as 鈥榮upplied as empty鈥� unless you sell the packaging to a:听

• large UK producer who fills or packs it听听
• large UK brand owner - who fills it to form part of a branded sales unit听

You can check if the organisation you鈥檙e selling to is on the list of large producers who have submitted data to the environmental regulators.听

Report packaging type data听

Large producers need to report whether the packaging:听听

• is household or non-household听
• commonly ends up in public bins听
• is a household or non-household drinks container听
• is reusable听
• becomes self-managed waste听

Small producers need to report:听听

• the total weight of waste packaging, excluding drinks containers听
• the weight and number of household drinks containers only听

Household and non-household packaging听听

There is separate guidance on how to assess household and non-household packaging.听听

Packaging that commonly ends up in public bins听听

You must collect and report data about the material and weight of the following household packaging items that commonly ends up in public bins:听

• packaging provided to consumers with take-away food or drink, including wraps, boxes, cups, cup-holders, bags and paper听
• packaging on confectionery, where the confectionery weighs less than 230g, including chewing gum packaging and chocolate wrappers听
• packaging on cigarettes, cigars, tobacco, e-cigarettes and vaping refills听
• packaging around straws - for example, a paper or cellophane wrapper听
• crisp packets or packaging on other savoury snacks, where the crisps or snacks weigh less than 60g听
• packaging on single portions of food which can be consumed immediately without further preparation, including sausage rolls, sushi, sandwiches, biscuits and individual cakes听
• cartons holding 850ml or less of drink, whose contents can be consumed immediately without dilution听
• pouches containing less than 600ml of drink, whose contents can be consumed immediately without dilution听

You only need to report this data in this category. You should not report it as household packaging as well.听听

The list of items that commonly end up in public bins is reviewed regularly and may change at the end of the reporting year.听听

There are detailed illustrations and examples in the 鈥榓greed positions and technical interpretations鈥� guidance, produced by the environmental regulators. It is currently stored on .听听

Drinks containers听听

Drinks containers include single-use bottles or cans for drinks. They should be made wholly or mainly of any of the following materials:听听

• polyethylene terephthalate (PET) plastic听
• 驳濒补蝉蝉听
• 蝉迟别别濒听
• 补濒耻尘颈苍颈耻尘听

Drinks containers should hold 150ml to 3l of liquid. This includes containers that are 150ml to 3l and supplied in multipacks.听听

Takeaway cups do not count as drinks containers.听听

Reporting lids, labels and other parts听

If the drinks container has other parts made of different material, like a lid or a label (also known as 鈥榓ncillaries鈥�), report these:听

• separately, as primary household packaging for glass drinks containers听
• as part of the total weight of the container for steel, aluminium and PET drinks containers听 - report the container as whatever material makes up most of the weight听

How large organisations should report drinks containers data听

You must split your drinks containers data into 2 categories:听听

• household drinks containers听
• non-household drinks containers听

There is separate guidance on how to assess household and non-household packaging .听听

How small producers should report drinks containers data听

You should record all of your drinks containers as 鈥榟ousehold drinks containers鈥�.听听

Reusable packaging听

Large organisation need to report packaging that鈥檚 designed to be reused the first time it鈥檚 supplied. You will need to split it into 2 categories:听听

• reusable packaging that is primary packaging听
• reusable packaging that is non-primary packaging听

Self-managed packaging waste听

Large organisations report self-managed waste as either:听听

• consumer waste 鈥� such as waste you collect through a front of store take-back scheme to offset your household packaging听
• organisation waste 鈥� such as 鈥榖ackhauled鈥� waste听

For the self-managed waste you report, you need to tell us about any waste that鈥檚 collected in one UK nation and sent to another for recycling. For consumer waste you must only report data for waste that has been recycled.听听

You need to specify which nation the packaging was collected in and which it was sent to. This must be broken down by weight and material type.听听

For example, if you collect packaging waste in a grocery store in Scotland but move it to a distribution centre in England before it is sent for recycling, you will need to collect this data.听听

Self-managed consumer waste听

Self-managed consumer waste you report may be used to offset packaging you鈥檝e reported as household packaging. This will reduce your waste management fee.听听

You will need to report the total weight, broken down by material type. You must have evidence that it has been recycled.听听

There are 2 different types of self-managed consumer waste:听听

• recovered packaging waste that is not commonly collected by local authorities听
• reusable packaging waste听that鈥檚 been reused at least once

Add these together when you report your self-managed consumer waste.听听

Recovered packaging waste that is not commonly collected by local authorities听

You will need to report data about any packaging waste that you鈥檝e collected from consumers through a self-managed recycling scheme.听听

Examples of these schemes include:听听

• plastic bag collection points in supermarkets
• schemes that allow people to return empty crisp packets for recycling听

This only applies to packaging waste that is not commonly collected by local authorities.听听

If you recover waste from consumers that is commonly collected by local authorities, you should report this as 鈥榮elf-managed organisation waste鈥�.听听

Items that are commonly collected by local authorities for recycling听

The items that are commonly collected in all UK countries for recycling are:听听

• aerosols听
• bottles and jars听
• brown envelopes听
• cardboard sleeves听
• cereal boxes听
• corrugated cardboard听
• detergent and household cleaner bottles听
• drinks bottles听
• drinks cans听
• egg boxes听
• foil trays听
• food pots and tubs听
• food tins听
• fruit and vegetable punnets听
• margarine tubs听
• milk bottles听
• toilet roll tubes听
• toiletries and shampoo bottles听
• plastic trays听
• window envelopes听
• yoghurt pots听

In England, local authorities also commonly collect for recycling:听听

• foil听
• shredded paper听

In Northern Ireland, local authorities also commonly collect for recycling:听听

• Tetra Pak and liquid food and drink cartons听

In Scotland and Wales, local authorities also commonly collect for recycling:听听

• foil听
• lids from glass jars听
• shredded paper听
• Tetra Pak and liquid food and drink cartons听

Reusable packaging waste听

This is waste from packaging which:听听

• has been designed to be re-used and refilled multiple times听
• is now no longer being used as packaging - it has become waste听
• has been recovered from customers听

For example, this could include glass milk bottles that are no longer usable that you have sent for recycling.听听

How offsetting works听

The self-managed consumer waste that you report may be used to offset packaging you鈥檝e reported as household packaging. This will reduce your waste management fee.听听

You can only offset your household packaging if the material you have collected as part of your self-managed consumer waste is the same packaging material as the household packaging you鈥檝e reported.听听

For example, if you have collected plastic carrier bags for recycling, as part of a front of store take-back scheme, you can offset this against any plastic packaging you鈥檝e reported in the household packaging category. However, if you have not reported any plastic packaging, there will be no offset applied.听听

Self-managed organisation waste听

You will also need to collect data about all of the packaging waste that you have collected yourself on-site.听听

This could include 鈥榖ackhauling鈥� or where you鈥檝e arranged for packaging waste to be removed by a private contractor.听听

This can include:听听

• your own branded packaging waste听

• other brands鈥� packaging waste听
• packaging waste you鈥檝e received from another organisation for 鈥榖ackhauling鈥櫶�
• unbranded packaging waste听
• packaging waste you鈥檝e recovered from consumers that is commonly collected by local authorities听

For example, you may remove tertiary or secondary packaging from products before displaying them to customers. After removing this packaging, you arrange for it to be collected from your site by a private contractor and sent for recycling. In this instance, you should collect this data and record it in this category.听听

Report packaging class data听

Packaging class describes the purpose of the packaging and is split into four categories.听听

Primary packaging听

Primary packaging is what鈥檚 used to contain a single 鈥榮ales unit鈥� to sell to customers. For a sales unit that鈥檚 made up of lots of items, such as a multipack, the primary packaging includes all of the packaging on the items.听

For example, if you sell peas in steel tins with paper labels, the primary packaging is 鈥榮teel tin鈥� and 鈥榩aper label鈥�.听听

For a multipack of crisps in plastic bags, the primary packaging is the 鈥榩lastic bags鈥� around the crisps and the larger 鈥榩lastic bag鈥� around the crisp packets.听听

Secondary packaging听

Secondary packaging is for grouping several 鈥榮ales units鈥� for selling or transport purposes. Organisations may also use secondary packaging to display goods in shops.听

For example, if you place tins of peas onto a cardboard tray and place the tray onto a supermarket shelf, the secondary packaging is 鈥榗ardboard tray鈥�.听听

Shipment packaging听

Shipment packaging is any packaging added to primary packaging for goods sold online or by mail order and delivered directly to the purchaser or to a shop or collection point. Shipment packaging can include cardboard boxes, bubble wrap and mail bags.听

For example, if you sell a mobile phone directly to a purchaser online, in a cardboard box and then place the box into a mail bag before posting it, the primary packaging is the cardboard box and the mail bag is shipment packaging.听

Tertiary packaging听

Tertiary or transit packaging is used to group secondary packaging units together to protect them while being transported or handled through the supply chain.听

Tertiary packaging does not include road, rail, ship and air containers.听

For example, if secondary packaging units are placed into larger cardboard boxes that are sealed with plastic parcel tape and put onto wooden pallets to be transported, the tertiary packaging is 鈥榗ardboard box鈥�, 鈥榩lastic tape鈥� and 鈥榳ooden pallet鈥�.听听

Report packaging material and weight data听

Small and large producers must report the weight in kilograms (kg) of the individual materials for each packaging activity you carry out.听听

Types of material听

You should report data for the following materials:听听

• 补濒耻尘颈苍颈耻尘听
• fibre-based composite听
• 驳濒补蝉蝉听
• paper or cardboard听
• plastic听
• 蝉迟别别濒听
• wood听
• 鈥榦ther鈥櫶�

鈥極ther鈥� includes any materials you use that are not listed here. For example, other materials could include:听听

• bamboo听
• ceramic听
• copper听
• cork听
• hemp听
• rubber听
• silicone听

You must report each material type separately.听听

If you report materials under 鈥榦ther鈥�, you must give the weight of each material type.听听

Composite and multi-material packaging听

Composite packaging is made of:听听

• 2 or more layers of different materials听
• materials that cannot be separated by hand听

For this sort of packaging, you should report the full weight of the packaging and should report it as the main material (the material that weighs the most).听

For example, a crisp packet contains plastic and foil. The main material is plastic, so you should report this as plastic.听听

You should class a material as 鈥榝ibre-based composite鈥� if both of the following are true:听听

• the main material contains paperboard or paper fibres听
• the material is laminated with plastic听

It may also have layers of other materials.听听

Multi-material packaging is made from components of different materials. Packaging is multi-material when it is possible to separate it by hand. For example, a yoghurt pot with a cardboard sleeve which can be removed by hand.听听

For this sort of packaging, you should record the weights of the different materials separately.听听

Record recyclability data听

From 1 January 2025, producers who supply household packaging must assess the recyclability of that packaging. The rating affects the disposal fee that will be charged for that packaging. This is sometimes called 鈥榝ee modulation鈥�.听

Large producers must report their first batch of RAM data by 1 October 2025. This will cover 1 January to 30 June 2025.听听

Small producers do not have to report RAM data.

Find out more by reading:听

• an overview of the RAM that explains the process听听
• how to assess and rate individual materials - use this to find red, amber or green ratings for your packaging materials听
• definitions and background - this explains the stages of recyclability and some technical terms听

Report nation data听

Nation data is information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in.听听

If your organisation must act under EPR for packaging, you must submit nation data if you also do any of the following:听听听

• supply filled or empty packaging to customers in the UK, where they are the end user of the packaging听
• supply empty packaging to UK organisations that are either not legally obligated, or are classed as a small organisationproducer听
• hire or loan out reusable packaging听
• own an online marketplace through which organisations based outside the UK sell their empty packaging and packaged goods to UK consumers听
• import packaged goods into the UK for your own use and discard the packaging听

Nation data should show where in the UK you鈥檝e supplied packaging to a person or business who鈥檚 gone on to discard it.听听

Supplying packaging includes:听听听听

• selling听
• hiring听
• loaning听
• gifting听
• providing in exchange for something other than money听
• providing because of a statutory duty听

This also includes packaging that you鈥檝e imported and then discarded.听听

How to report your data听

Report your data by submitting a file using the 鈥榬eport packaging data鈥� service.听听

Find out how to create your EPR for packaging data file.听听

Read guidance about when large and small producers need to report data.听

How parent companies should report data听听

If you have registered for EPR for packaging as a parent company, you must submit data for each of the subsidiaries within your group registration separately.听听

You do not need to include data for any of your subsidiaries that have registered independently.听听

Find out how EPR for packaging affects parent companies, groups and subsidiaries.听听

There are detailed illustrations and examples in the 鈥榓greed positions and technical interpretations鈥� guidance, produced by the environmental regulators. It is currently stored on .听

How your data will be used听听

Your data is used to work out your waste management fee and your recycling obligations.听听

The scheme administrator will use some of your data to calculate your waste management fee. To calculate this fee, they will look at your:听听

• household packaging data听
• packaging that commonly ends up in public bins data听

Packaging data that鈥檚 been reported under the 2007 regulations (鈥榯ransitional reporting鈥�)听

A one-year transitional provision lets organisations discount a portion of their packaging from their recycling obligations if it鈥檚 already been reported under the 2007 producer responsibility regulations.听This does not discount any waste disposal fees.听听

This is also known as the 鈥榙ual reporting鈥� or 鈥榯ransitional reporting鈥� provision.听听

If you have submitted packaging under the 2007 regulations, met your recycling obligations on this and want the discount to be applied to your obligations for 2025, you must calculate the amount to be discounted and submit this as part of your 2024 packaging data.听听听

This only applies to large organisations.听

There are detailed illustrations and examples in the 鈥榓greed positions and technical interpretations鈥� guidance, produced by the environmental regulators. It is currently stored on .听

How to calculate the discount听

You must multiply two figures.听听

First, the amount of packaging, in kilograms, where all the following are true:听听听

• a proportion of the packaging was reported under the 2007 regulations
• someone has met the recycling obligation on the 2007 reporting听听
• you鈥檝e had to report it again under EPR听

This should be done separately for each material.听听听

Secondly, the sum of all the applicable obligations that were applied to it under the 2007 regulations. These are the percentages set out in those regulations - for example, a manufacturer picks up 6% of the recycling obligation, a convertor 9% and a packer/filler 37%.听听

You鈥檒l have to be able to provide evidence that the recycling obligation has been met for any packaging that you want to discount under this provision.听听听听

Example: applying the discount听

An item of packaging was manufactured, converted and packed in the UK in 2023, then supplied to the end user in 2024. Under the 2007 regulations, the manufacturer, convertor and packer would pick up 52% of the total recycling obligation - the seller would pick up the remaining 48%.听听听

The manufacturer, convertor and packer would collect the data in 2023 and report it in 2024, under the 2007 regulations. The seller鈥檚 obligation (48%) would not come under the 2007 regulations because it was supplied in 2024.听听听听

In 2024 an organisation supplies the same packaging under EPR for packaging. The large organisation will have a recycling obligation in 2025 for 100% of the packaging it supplied in 2024.听听

This means a total recycling obligation of 152% has been created. Under the one-year provision, the organisation obligated under EPR for packaging will be able to discount the excess 52%.听听

If they were reporting 10,000 kg of the material again, they would apply the formula above as follows:听听

10,000 kg x 52% = 5,200 kg听听

They would then report both figures:听听

• 10,000kg of packaging before the discount听听
• 5,200kg of packaging to be discounted听

How to report the amount you want discounted听

You鈥檒l submit this as part of your packaging data for the second half of 2024. You鈥檒l have to submit this by 1 April 2025.听听

The guidance on how to structure your packaging data explains where you will need to add this information to your submission.听

Examples of how to report data听

These examples show how you should report your packaging data. They do not show how to report nation data.听听

Example 1: Imported supermarket groceries听听

A UK wholesaler imports broccoli from France. It sells the broccoli to a supermarket in the UK. The supermarket then sells the broccoli to consumers under its brand name. The supermarket was responsible for the import of the broccoli and makes this clear on the label.听听

When the broccoli arrives in the UK, it鈥檚 already wrapped in plastic film with a paper label, which has the supermarket鈥檚 brand on it. It is stored in a wooden crate.听听

The wholesaler takes the broccoli out and sends the crate back to France, where it is used again. The wholesaler packs the broccoli into unbranded reusable plastic trays (such as IFCO trays). They put the plastic trays onto hired wooden pallets and secure them with unbranded shrink wrap. They send the pallets to a supermarket.听听

The supermarket removes the shrink wrap and the pallets. They put the plastic trays onto the shelves for customers to access them. The supermarket sends the reusable plastic trays back to the wholesaler when they are empty. The supermarket recycles the shrink wrap and sends the pallets back to the hiring company.听听

After a consumer has bought broccoli, they remove the plastic film and label and put it into their bin.听听

Who needs to collect data?听听

• the wholesaler听
• the supermarket听
• the hiring company听

Packaging material they should record听听

• shrink wrap听
• reusable plastic trays听
• plastic film protecting the broccoli听
• labels听
• pallets听

The wooden crates that the broccoli was shipped in do not need to be reported. This is because they were sent to another country to be reused.听听

Data the wholesaler should collect听听

The wholesaler needs to report the shrink wrap and the reusable plastic boxes.听听

They should record the following information for the shrink wrap:听听

• packaging activity: packed or filled as unbranded听
• packaging type: non-household听
• packaging class: tertiary packaging听
• packaging material and weight: plastic听

They only need to report the reusable plastic boxes the first time they are used. They should record the following 2 data entries for the plastic boxes.听听

First data entry:听听

• packaging activity: packed or filled as unbranded听
• packaging type: non-household听
• packaging class: secondary packaging听
• packaging material and weight: plastic听

Second data entry:听听

• packaging activity: packed or filled as unbranded听
• packaging type: reusable听
• packaging class: non-primary packaging听
• packaging material and weight: plastic听

Data the supermarket should collect听听

The supermarket needs to report the plastic film protecting the broccoli and the labels that have the supermarket鈥檚 brand on them.听听

They should record the following data for the plastic film:听听

• packaging activity: supplied under your brand听
• packaging type: household听
• packaging class: primary packaging听
• packaging material and weight: plastic听

They should record the following data for the labels:听听

• packaging activity: supplied under your brand听
• packaging type: household听
• packaging class: primary packaging听
• packaging material and weight: paper听

Data the hiring company should collect听听

The hiring company needs to report the wooden pallets. They only need to do this the first time they hire them out. They should record the following 2 data entries for the wooden pallets.听听

First data entry:听听

• packaging activity: hired or loaned听
• packaging type: non-household听
• packaging class: tertiary packaging听
• packaging material and weight: wood听

Second data entry:听听

• packaging activity: hired or loaned听
• packaging type: reusable听
• packaging class: non-primary packaging听
• packaging material and weight: wood听

Example 2: Heat pumps made abroad听听

An engineering organisation makes heat pumps for people鈥檚 homes. They sell them to trade outlets and heat pump installers. The pumps are made in Ireland by the engineering organisation and are shipped to the UK.听听

After they are made in Ireland, the pumps are put into cardboard boxes that show the engineering organisation鈥檚 brand. The boxes are put into a container and shipped to the UK distribution centre of the engineering organisation.听听

For the pumps that are sent to installers, the engineering organisation places each pump on a wooden pallet. They also place other parts onto the pallet, such as pipes, lubricants and other components. These parts are in unbranded plastic wrap. They secure the pallet with shrink wrap and send it to the installer.听听

The installer removes all the packaging and recycles it. The installer does not send any of the packaging back to the engineering organisation.听听

For the pumps that are sent to trade outlets, the pumps are placed onto pallets owned by the engineering organisation, with 6 on each one. The pallets are secured with shrink wrap and sent to trade outlets.听听

The trade outlet removes the shrink wrap and recycles it. They send the pallets back to the engineering organisation. They put the heat pumps onto their shelves.听听

They sell the heat pumps in their cardboard boxes. Some go directly to consumers, and some to heat pump installers.听听

The installers and consumers remove the cardboard boxes and recycle them.听听

Who needs to collect data?听听

The engineering organisation is the only one who needs to report data, in this instance.听听

Who does not need to collect data?听听

The trade outlets and the heat pump installers do not need to report.听听

Data the engineering organisation should collect听听

The engineering organisation needs to collect data about the following packaging materials:听听

• cardboard boxes听
• pallets听
• shrink wrap听
• plastic wrap听

They should collect the following data for the cardboard boxes:听听

• packaging activity: supplied under your brand听
• packaging type: household听
• packaging class: primary packaging听
• packaging material and weight: paper or cardboard听

They only need to report the returned pallets the first time they are used. They should collect the following 2 data entries about the pallets sent to trade outlets.听

First data entry:听听

• packaging activity: packed or filled as unbranded听
• packaging type: non-household听
• packaging class: tertiary packaging听
• packaging material and weight: wood听

Second data entry:听听

• packaging activity: packed or filled as unbranded听
• packaging type: reusable听
• packaging class: non-primary packaging听
• packaging material and weight: wood听

For the pallets sent to installers (that are recycled), they should collect the following data:听听

• packaging activity: packed or filled as unbranded听
• packaging type: non-household听
• packaging class: tertiary packaging听
• packaging material and weight: wood听

They should collect the following data for the shrink wrap:听听

• packaging activity: packed or filled as unbranded听
• packaging type: non-household听
• packaging class: tertiary packaging听
• packaging material and weight: plastic听

They should collect the following data for the plastic wrap:听听

• packaging activity: packed or filled as unbranded听
• packaging type: household听
• packaging class: primary packaging听
• packaging material and weight: plastic听

If you need to see the rules for data from 2023听

This guidance covers data collected from 2024 onwards. You can to see the rules for data from 2023.听

Contact the regulators if you need to report your data from 2023 but have not yet done so.听

Get help and give feedback听听

If you have any questions, contact the packaging team.听听

Email: packaging@defra.gov.uk听听

Defra is looking for waste and packaging professionals to join a user panel to help improve our services. Find out more information and .听