Updated: 25 August 2026

UK businesses that supply or import packaging now have clearer guidance on how to register and report packaging data under Extended Producer Responsibility for packaging, commonly referred to as packaging EPR or pEPR.

On 19 August 2026, the Department for Environment, Food & Rural Affairs updated several key parts of its packaging EPR guidance. The changes include consolidated registration guidance, new registration templates, updated reporting-file guidance, 2026 example files and refreshed reporting deadlines.

For producers, the practical message is straightforward:

Packaging EPR is now an operational data-compliance requirement. Businesses need to know whether they are obligated, classify packaging correctly, maintain sufficiently detailed packaging records and submit them in the required format by the applicable deadline.

This guide explains the August 2026 changes and what UK producers should do next.

What changed in the August 2026 EPR update?

The August update should not be interpreted as an entirely new EPR law.

Instead, Defra has substantially clarified and reorganised the operational guidance businesses use to comply with the existing packaging EPR regime.

The main developments are:

  • updated guidance for determining whether an organisation is an obligated producer
  • clearer registration requirements
  • registration-file templates
  • updated packaging-data file specifications
  • dedicated 2026 example reporting files
  • a 2026 packaging-data file generator
  • clearer reporting deadlines for large and small producers
  • updated information about resubmitting packaging data
  • clearer treatment of holding companies and subsidiaries

Defra’s central EPR collection was last updated on 19 August 2026 and now brings together the current producer, reporting, registration and compliance guidance.

What is UK packaging EPR?

Extended Producer Responsibility for packaging transfers more responsibility for packaging waste onto businesses that place packaging on the UK market.

A business may have EPR obligations when it supplies or imports packaging or packaged products.

Activities potentially caught by the regime include:

  • supplying products in packaging under your own brand
  • placing goods into packaging
  • importing packaged products
  • supplying empty packaging
  • hiring or loaning reusable packaging
  • operating certain online marketplaces

The precise obligated party depends on the activity being performed and the circumstances in which the packaging is supplied.

This means EPR should not be assessed simply by asking:

“Does our company use packaging?”

The better questions are:

Who supplies it?
Who owns the brand?
Who imports it?
Who fills it?
Who sells it to the end user?
How much packaging is placed on the UK market?

Those questions determine where the reporting responsibility sits.

Do you qualify as a small or large EPR producer?

Two factors are particularly important:

  1. annual turnover
  2. the amount of packaging supplied or imported

For the current rules, the government’s threshold table is:

Packaging supplied or importedTurnover £1m or lessTurnover £1m–£2mTurnover above £2mLess than 25 tonnesNo obligationNo obligationNo obligation25–50 tonnesNo obligationSmall producerSmall producerMore than 50 tonnesNo obligationSmall producerLarge producer

Therefore, a business with turnover above £2 million does not automatically become a large producer.

It generally also needs to supply or import more than 50 tonnes of packaging.

Likewise, the term small producer under EPR does not refer to employee numbers. It is a regulatory classification based on turnover and packaging tonnage.

What must large producers do?

Large producers carry the most extensive packaging EPR obligations.

Under current government guidance, a large producer must:

  • register with its environmental regulator each year
  • report packaging data every six months
  • meet applicable packaging recycling obligations
  • obtain sufficient PRNs, PERNs or a combination of both
  • submit a certificate of compliance
  • pay applicable waste-disposal fees for household packaging
  • retain required records for seven years

These requirements make packaging classification and data quality financially significant, not merely administrative.

What must small producers do?

Small producers have fewer obligations, but they are still within the packaging EPR system.

They must generally:

  • register for packaging EPR
  • renew registration annually
  • collect the required packaging information
  • report packaging data annually

Current government guidance states that small producers do not pay the household packaging waste-disposal fee and do not need to purchase PRNs or PERNs.

That distinction is important.

Being an EPR-obligated producer does not mean every organisation has exactly the same financial obligations.

What are the next EPR reporting deadlines?

As of 25 August 2026, the next major deadline for a large producer is:

1 October 2026

This covers packaging supplied between:

1 January 2026 and 30 June 2026.

Large producers report every six months.

The subsequent reporting period is:

1 July–31 December 2026 → deadline 1 April 2027.

Small producers report once annually.

The next small-producer deadline is:

1 April 2027

This covers packaging supplied during:

1 January–31 December 2026.

Defra confirmed these deadlines in guidance updated on 19 August 2026.

Current reporting calendar

ProducerPackaging periodReporting deadlineLarge1 Jan–30 Jun 20261 Oct 2026Large1 Jul–31 Dec 20261 Apr 2027Small1 Jan–31 Dec 20261 Apr 2027

Businesses approaching the October deadline should therefore already have their H1 2026 packaging records reconciled.

There is also a 1 September 2026 resubmission deadline

One deadline deserves particular attention.

Government guidance currently states that the new deadline for resubmitting 2025 packaging data is 1 September 2026.

Businesses that discover mistakes in an existing return should not assume that changing submitted packaging data is cost-free.

The guidance lists resubmission fees of:

  • £807 for organisations registered directly with their environmental regulator
  • £512 for organisations registered through a compliance scheme

as at the date of this article.

This makes pre-submission validation increasingly important.

What does the new packaging reporting file look like?

One of the most useful August developments is Defra’s updated guidance on creating the packaging-data reporting file.

Packaging data is submitted through the government’s Report Packaging Data service, commonly abbreviated to RPD.

Defra has now published example files for 2026 covering:

  • large producers — 2026-H1
  • small producers — 2026-P0
  • compliance schemes — including 2026-H2 and 2026-P0

It has also published a Packaging Data File Generator 2026.

The Excel-based generator contains built-in validation and generates outputs that can be saved as a CSV file for submission through the government service.

H1, H2 and P0 explained

The time-period codes are important.

H1 = first six months of the year for large producers.

H2 = second six months of the year for large producers.

P0 = annual reporting period used for small producers.

Businesses should not invent their own spreadsheet structure and assume it will upload successfully.

The government’s reporting specification defines the required fields and permitted codes.

What information goes into an EPR packaging data file?

The information required depends on the producer type and packaging involved, but EPR reporting can require classification across several dimensions.

These include:

Packaging activity

This describes why your organisation is responsible for the packaging.

For example, responsibility may arise because the organisation is a:

  • brand owner
  • packer or filler
  • importer
  • distributor
  • marketplace operator
  • supplier of empty packaging

Packaging material

Businesses must identify what the packaging is made from.

This can include materials such as:

  • plastic
  • paper or board
  • glass
  • aluminium
  • steel
  • wood
  • fibre-based composite
  • other materials

Packaging class

Packaging may also need to be classified according to its function within the packaging system.

For example:

  • primary packaging
  • secondary packaging
  • shipment packaging
  • tertiary packaging

Packaging weight

Reported packaging quantities need to be supported by reliable weight information.

For complex product catalogues, this can involve thousands of individual packaging components.

Household status

Large producers may also need to determine whether relevant packaging is:

  • household packaging
  • non-household packaging

That classification matters because household packaging can generate EPR waste-disposal fee liability.

This is one of the areas where weak packaging master data can quickly become a compliance problem.

Registration data is separate from packaging data

Another source of confusion is the difference between the registration file and packaging-data reporting file.

They are not the same thing.

Registration file

The registration file contains information about the organisation.

Defra states that this can include:

  • organisation address
  • annual turnover
  • packaging activities
  • contact details
  • approved or delegated persons
  • brand information where applicable
  • partnership information where applicable

Organisations registering directly submit this information through the Report Packaging Data service.

A registered compliance scheme can register a producer on its behalf.

Packaging reporting file

The reporting file contains the packaging activity data itself.

This is where the relevant packaging quantities, categories, material classifications and regulatory codes are reported.

Keeping these two datasets separate is essential when designing an internal EPR process.

What about groups and subsidiaries?

Group structures require additional care.

For EPR purposes, a holding company must consider qualifying members of its corporate group when assessing whether the group meets the producer thresholds.

For 2026 packaging data, current Defra guidance requires relevant groups to consider packaging supplied or imported during 1 January to 31 December 2025, alongside the applicable turnover information.

Where the group satisfies the relevant threshold, individual members can be treated as large or small producers even where they would not individually reach the threshold.

This means assessing companies in isolation can produce the wrong EPR conclusion.

Can a compliance scheme submit EPR data for you?

Yes.

Businesses do not necessarily have to administer every EPR submission internally.

Defra states that producers can use a registered compliance scheme, including for activities such as registration and packaging-data reporting.

However, using a third party does not remove the need to maintain accurate source data.

A compliance provider can only report accurately if the underlying packaging information supplied by the producer is reliable.

The major EPR risk is increasingly data quality

For many organisations, the difficult part of packaging EPR is not uploading the CSV.

It is producing defensible data before the CSV is generated.

Typical data issues include:

  • incomplete packaging bills of materials
  • missing component weights
  • incorrect material classifications
  • inability to distinguish household from non-household packaging
  • inconsistent packaging information across suppliers
  • duplicated product records
  • missing imported packaging
  • incorrect obligated-party determination
  • group companies assessed independently when they should be considered together
  • changes to packaging specifications not reflected in reporting systems
  • no reconciliation between procurement, sales, logistics and packaging records

These issues can affect reporting accuracy and, for large producers, potentially affect recycling obligations and waste-disposal costs.

EPR is moving from reporting towards packaging design

Packaging EPR should also be considered alongside the UK’s Recyclability Assessment Methodology.

From the 2026/27 scheme year, household packaging disposal fees begin to be modulated according to recyclability.

PackUK’s modulation policy applies a factor of 1.2 to red-rated material in 2026/27, increasing to 1.6 in 2027/28 and 2.0 in 2028/29 under the current policy statement.

This changes the strategic question.

Previously, businesses might have concentrated primarily on:

“Can we report this packaging?”

Increasingly, they also need to ask:

“How will the design of this packaging affect our future EPR cost?”

Packaging data should therefore connect compliance, procurement and packaging-design decisions.

What should producers do now?

Organisations affected by packaging EPR should establish a repeatable compliance process rather than treating each submission as a standalone spreadsheet exercise.

A practical workflow is:

1. Determine the obligated entities

Identify the relevant companies, group structure and packaging activities.

2. Confirm producer classification

Calculate turnover and packaging tonnage against the current small- and large-producer thresholds.

3. Build a packaging inventory

Identify products, packaging components, materials and weights.

4. Determine regulatory responsibility

Establish which party in the supply chain is responsible for each packaging item.

5. Classify the packaging

Apply the appropriate activity, material, class, household status and other required regulatory attributes.

6. Validate the source data

Check missing weights, duplicates, anomalous tonnages and inconsistent classifications.

7. Map the data to Defra codes

Transform the underlying packaging inventory into the current reporting specification.

8. Generate and validate the CSV

Use either the government’s generator or an internal system capable of producing the required file structure.

9. Reconcile before submission

Compare totals against purchasing, inventory, sales and previous reporting periods.

10. Maintain an audit trail

Retain evidence showing how packaging quantities and classifications were determined.

For large organisations, this should increasingly be treated as a controlled data-management process rather than a once-every-six-months compliance task.

How SustainZone approaches packaging EPR readiness

SustainZone supports businesses in organising the data required for environmental compliance.

For packaging EPR, this can include:

  • producer-obligation assessment
  • packaging-data collection
  • supplier-data structuring
  • household and non-household packaging classification
  • packaging material and component mapping
  • reporting-file preparation
  • data validation
  • evidence and audit-trail management
  • reporting readiness
  • RAM and packaging recyclability analysis

Where statutory submission or compliance-scheme functions require an appropriately registered or accredited organisation, those functions should remain with the producer, its registered compliance scheme or the relevant authorised party.

The objective is to make the underlying packaging data complete, structured, traceable and submission-ready.

Frequently asked questions

What is the next UK packaging EPR reporting deadline?

For large producers, the next packaging-data reporting deadline is 1 October 2026, covering packaging supplied from 1 January to 30 June 2026. Small producers next report by 1 April 2027 for the 2026 calendar year.

Do small producers have to report packaging data?

Yes. An organisation classified as a small producer under packaging EPR must generally register and submit packaging data annually.

Do small EPR producers need PRNs?

Current government guidance states that small producers do not need to purchase PRNs or PERNs and do not pay EPR waste-disposal fees.

How often do large producers report packaging data?

Large producers report packaging data every six months.

Is the EPR registration file the same as the packaging-data file?

No. The registration file contains information about the organisation, while the packaging-data reporting file contains the packaging information required for the reporting period.

Can a compliance scheme submit packaging data?

Yes. A registered packaging compliance scheme can perform certain registration and reporting activities on behalf of an obligated producer.

What service is used to submit EPR packaging data?

Packaging EPR registration and packaging-data submissions are handled through the government’s Report Packaging Data service.

Regulatory note: This article reflects UK government guidance available on 25 August 2026. Packaging EPR requirements depend on the specific activities and circumstances of an organisation. Government guidance and regulations should be checked before making a formal compliance determination.