Under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (“pEPR”), any small or large producer that is a seller and supplies plastic or paper bags in England must submit an annual report to the Environment Agency (EA) on the quantity of those bags.
As we move through the 2025 compliance year, it is important that producers understand this reporting obligation. This article outlines who is required to report this data, what is classed as a bag under this regulation, what must be reported, and what the reporting deadlines are.
Regulatory obligation under pEPR
The requirement to report plastic and paper bags is set out in Regulation 38 of the 2024 pEPR Regulations, titled “Obligation to report data on plastic or paper bags supplied in England”.
It applies in addition to the main data reporting duties in pEPR Regulations (core packaging data, nation of sale data, and recyclability assessments). This new targeted reporting requirement is designed to give government better visibility over carrier bag use in England.
Who must report?
The bag reporting duty applies only if both are true:
- You are an obligated EPR producer (small or large), and
- You are a seller who supplies plastic or paper bags in England.
EPR producer thresholds
You must engage with EPR, and therefore may have bag reporting duties, if all the following apply:
- You’re an individual business, group, or subsidiary (not a charity), established in the UK.
- Your annual turnover is £1m or more.
- You were responsible for more than 25 tonnes of packaging in the previous calendar year; and
- You carry out at least one EPR packaging activity (brand owner, pack/fill, importer, distributor, seller, online marketplace, service provider, supplier of empty packaging).
Within these thresholds there are two categories:
Small producer:
- Turnover >£1m and up to £2m, and >25 tonnes of packaging or
- Turnover >£1m and between 25–50 tonnes of packaging.
Large producer:
- Turnover ≥£2m and >50 tonnes of packaging.
Both small and large producers who are sellers and supply in-scope bags in England must report bag data.
“Seller” in this context
Under pEPR, a seller is the producer function that supplies filled packaging (or packaged goods) to the end user e.g. supermarkets, high-street retailers, etc.
Therefore, the bags will be reported by the producer who supplied them to the ‘final user’ (customer).
Which bags are in scope?
The following bags are in scope where they are supplied to customers in England:
- Bags within the description of the Single Use Carrier Bags Charges (England) Order 2015, (e.g. 10p plastic shopping bags).
- “Paper bags, of any thickness, which have handles, and which are not sealed.”[1]
- “Bags made wholly or partly of plastic”[1] which are supplied for use as packaging for food items such as bread, fruit or vegetables; and are carrier bags that are not described under the Single Use Carrier Bags Charges (England) Order 2015.
What must be reported
Producers must report:
- The number of plastic and paper bags supplied in England,
- Categorised into the separate bag classifications as mentioned above.
- Single use carrier bags
- Paper handled bags
- Bags made wholly or partly of plastic used as food packaging.
Although bag reporting is a data-only obligation with no additional fees at present, the Environment Agency can use its new civil sanctions to respond to inaccurate or missing data – including for plastic and paper bags.
Reporting deadlines
- Reporting period: Calendar year (1 January – 31 December).
- First deadline: 1 April 2026, for bags supplied in 2025.
This then becomes a recurring annual duty (1 April each year for the previous calendar year).
This annual bag report will sit alongside:
- Your six-monthly packaging data reports (for large producers).
- Your annual packaging data report (for small producers).
- Any recyclability assessment (RAM) submissions (for liable large producers).
- Nation-of-sale /nation-of-discard data, once fully enforced.
Comply with Clarity
We know how difficult and time-consuming it can be to keep on top of new regulatory obligations such as bag reporting under pEPR.
Clarity’s compliance team can help you:
- Understand whether the plastic and paper bag reporting duty applies to your business.
- Set up robust data collection processes for 2025 and beyond.
- Prepare and submit accurate EPR data, including your annual bag report.
With over 600 members, our experts already handle thousands of lines of packaging data for producers of all sizes, from small UK brands to large retail groups. If you would like support assessing your obligations or preparing your 2025 bag report, please contact your usual account manager or get in touch via our website.
[1] 14., Schedule 4, The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024
