Extended Producer Responsibility Data Collection

Extended Producer Responsibility Data Collection

What data do you need to collect?

You must collect data about the packaging you’ve supplied through the UK market or imported into the UK.

The data you collect must include the following categories:

• packaging activity – this is how you supplied the packaging
• packaging type – for example, if the packaging is household or non-household
• packaging class - whether the packaging is primary, secondary, shipment or tertiary
• packaging material and weight. Please see further details at https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility#packaging-material-and-weight-data

You may also need to collect 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.

Household and non-household packaging

You must submit the weight of packaging that is:

• household
• non-household

What is classed as household packaging?

• primary packaging
• shipment packaging

If you supply primary or shipment packaging to a business which supplies it on to another business or an end-consumer, with any packaging included, all packaging should be reported as household packaging. For example, you may supply packaging to a business through a third party such as a distributor or wholesaler.

If you have clear evidence that some of your primary and shipment packaging is supplied directly to a business that is the end user of all the packaging, you do not need to report it in this category.

What is classed as non-household packaging?

You should class the following packaging as non-household:

• secondary packaging
• tertiary packaging

You should also class primary or shipment packaging as non-household packaging if you supply it to a business which is either of the following:

• the end-consumer of the goods contained in the packaging
• an organisation that supplies the goods to an end-consumer with all of the packaging removed

You need to be able to show evidence of this. If you cannot, you must class this packaging as household.

Packaging activity data

You need to tell HMRC what your role was when you supplied the packaging in the UK. You do this by breaking down your data into the different packaging activities. These are:

• supplied under your brand
• packed or filled as unbranded
• imported
• supplied as empty
• hired or loaned
• supplied through an online marketplace that you own

If you supply packaged goods to the UK market you may need to report ‘nation data’. You can find out more about this in the ‘check if you need to report nation data’ section.

‘Supplied under your brand’ packaging

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

• a name
• a trademark
• any distinguishing mark

This applies to all packaging that contains goods, where one or more of the pieces of packaging display your brand.

For example, you may supply a ready meal inside an unbranded plastic tray with film, with a branded carboard sleeve. In this instance, the plastic tray and film should be included as part of the data you report in the ‘supplied under your brand’ category.

Primary, secondary, shipment and tertiary packaging can all be classed as ‘supplied under your brand’ packaging.

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

• produce goods that you’ve gone on to supply under your brand name
• pack goods that you’ve gone on to supply under your brand name
• supply your branded goods to the UK market
• import your branded goods for you

Packaging type data

You also need to tell HMRC what type of packaging you supply.

Large organisations will need to report whether the packaging:

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

Small organisations need to report:

• their total packaging weight, excluding drinks containers
• drinks containers

If you’re a small organisation you do not need to break down your data into the other packaging types.

Packaging class data

Primary packaging

Primary packaging is what’s used to contain a single ‘sales unit’ to sell to customers. For a sales unit that’s made up of lots of items, such as a multipack, the primary packaging includes all of the packaging on the items.

For example, if you sell peas in steel tins with paper labels, the primary packaging is ‘steel tin’ and ‘paper label’.

For a multipack of crisps in plastic bags, the primary packaging is the ‘plastic bags’ around the crisps and the larger ‘plastic bag’ around the crisp packets.

Secondary packaging

Secondary packaging is for grouping several ‘sales units’ for selling or shipping purposes. Organisations may also use secondary packaging to display goods in shops.

For example, if you place tins of peas onto a cardboard tray and place the tray onto a supermarket shelf, the secondary packaging is ‘cardboard tray’.

Shipment packaging

Shipment packaging is for shipping single or multiple sales units directly to consumers. This includes cardboard boxes, bubble wrap and mail bags.

For example, if you place a mobile phone in a cardboard box and then place the box into a mail bag before shipping it, the shipment packaging is ‘mail bag’. The primary packaging is ‘cardboard box’.

Tertiary packaging

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

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

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 ‘cardboard box’, ‘plastic tape’ and ‘wooden pallet’.

Check if you need to report nation data

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

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

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

You will need to submit your nation data for the 2023 calendar year by 1 December 2024.

Nation data should show where in the UK you’ve supplied packaging to a person or business who’s gone on to discard it.

Supplying packaging includes:

• selling
• hiring
• loaning
• gifting

This also includes packaging that you’ve imported and then discarded.

 

---