New clarifications to packaging EPR data requirements aim to streamline reporting for UK producers

As the UK prepares for the full rollout of Extended Producer Responsibility (EPR) for packaging, Defra and the Environment Agency have issued a new set of clarifications designed to simplify the way producers collect and report data. Released in mid‑February, the updated guidance provides much‑needed clarity for brands, manufacturers and packaging suppliers as they prepare for the next phase of regulatory expectations.

For packaging producers and supply‑chain partners across the UK, these changes signal an important shift: more consistent reporting, clearer definitions, and a stronger push toward accountability.

Key clarifications:

1. Reusable packaging must now be reported twice – once when it enters the market and again when it completes a reuse cycle.
2. Hired and loaned packaging responsibilities rest with service providers, removing ambiguity for rental‑based systems.
3. Household drinks containers are now included in plastic subtype reporting.
4. The definition of tertiary packaging has been corrected to better reflect supply‑chain usage.
5. Shipment packaging is now defined broadly to include all tertiary packaging supplied to consumers.
6. ‘Supplied’ replaces ‘reported’ as the trigger for legal responsibility.

These updates will influence how data is captured across processing and packaging lines, increasing demand for automated traceability tools and smart factory integration. For many manufacturers, the adjustments may prompt investment in systems capable of exporting SKU‑level data, logging material types, and supporting compliance without additional manual work.

Businesses are encouraged to review their data‑collection processes and ensure all reusable, hired, loaned and shipment packaging flows are accurately mapped ahead of upcoming EPR phases.